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
1. Ask questions.
If something is unclear to you, ask for clarification. If more detail or more research is required, let the agency know. Be specific and give examples. Missing information is detrimental to the decision-making process. This is a particularly useful tip in the scoping process, when agencies are soliciting feedback on what issues the public is most concerned about with regards to a proposed project.
2. Stay objective, but passionate.
Many comments received on EISs are from people who are concerned with a project’s impact on their lives. They are either in favor of or against the project, and their comment states as much. Always try to consider the broader picture, how the project will impact not only you, but also your community, the state, or the nation, either in positive or negative ways. Try to stay objective, but don’t let that veil your passion. Positive change rarely ever comes from a perspective of disinterest.
3. Follow the rules.
Know when the public comment period opens and closes, what format an agency has requested comments be made in, and submit your comments accordingly. You don’t want your comment to be overlooked simply because you missed the deadline.
4. Attend local meetings.
If you have the opportunity to attend a public meeting, jump on it. Meeting attendance is a strong representation of public opinion. If no one shows up, the agency will think it’s because no one cares.
5. Do your homework.
If it’s available, read the EIS. It’s a good idea to focus on those topics that you are most interested in, but also read the conclusion, discussion of alternatives, and the described need for the project. These documents can be long, but for goodness sake, don’t just skim the summary.
6. Know who the key players are.
This is another element of doing your homework. Know who the stakeholders in the project are, including the project applicant, the lead agency, any cooperating agencies, and opposing interests. This could take a little research, but it is crucial to know who supports the project, who opposes the project, and why.
7. Mention what makes your comment relevant.
Are you a professional or academic with particular knowledge relating to your comment? Are you a local who knows of a better location for a development? State the facts and support them with a description about why you know what you know. This will add an element of credibility to your comment, and it’s possible that an agency might ask for more input to help in the decision-making process.
8. Avoid form letters.
Or, if you are committed to sending one, also send an originally worded comment. Hundreds of form letters can be received on a project, but the agency responds to all of them in the same way. Individual voices have a stronger impact when they are not obviously repeating the same message.

The internet has had a significant impact on the public comment process in recent years. More people are aware of and have access to decision-making documents such as EISs. Comments are now often accepted via email or web submittal rather than in person or through the mail. Take the opportunity to make your voice heard on issues that are important to you. And keep these tips in mind to make sure your comments are as effective as you want them to be.

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