1. Making Effective Comments
Verena Owen

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

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

4. 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
Copy the Regional Office

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

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

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

8. 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.

9. Examples
I believe that the facility should be regulated differently.

10. Examples
The applicable regulation for this facility is 40. CFR (a) because it produces more than4,550 kg of glass per day and is therefore not exempt under (c).

11. 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.

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

13. 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.