- WEB EXCLUSIVE
- PE COFFEEHAUS
The EPA regularly asks for comments from the public by placing an announcement in the Federal Register. It is my opinion that, sometimes, the agency sets the comment period too short in an effort to fast track the project. Occasionally, the agency tries that and gets overwhelmed by the public responses and they do increase the comment period.
In my opinion, the comment period should always be 90 days at a minimum. Potential responders may be away on vacation or on location for a project and they cannot keep up with the announcements. It takes time to organize and gather appropriate data for a proper response. Setting a comment period of 30 days does not allow everyone to be able to comment. In some cases, a potential responder must run his responses by his corporate superiors and/or legal team and that takes time to work through the process.
Public comments come in all forms. Some people will respond with an emotionally written letter that contains a lot of ranting but no substance. In some cases, there are tons of data but no way to know where the data came from or how it was derived. There may have been a lot of work to gather this data but it is totally useless and must be disregarded.
In most of the Federal Register notices, there are suggested guidelines from the EPA that really make a lot of sense. Following these guidelines will allow the people at the agency to give proper weight to the data and opinions in the comments. In spite of what a lot of people may think, the people at the EPA do work hard and try to do the right thing. Those that might have an agenda are few and far between and usually do not last.
Consider the following points when you submit your next comments to the EPA.
- Explain your views as clearly as possible and provide specific examples.
- Describe any assumptions that you used. Make sure to clearly identify them as assumptions.
copies of any technical information and/or data you used that support your
views. Clearly describe how the data was gathered.
- If you estimate potential burden or costs, explain how you arrived at the estimate that you provided. Show your calculations.
- Offer alternative ways to improve the collection activity.
- Make sure to submit your comments by the deadline identified under DATES. Late entries are usually not even read.
- To ensure proper receipt by EPA, be sure to identify the docket ID number assigned to this action in the subject line on the first page of your response. You may also provide the name, date, and Federal Register citation. While this may seem like common sense, it is often let out and usually means the data is not considered.