Preparing to Comment

• Author: Elizabeth D. Mullin
• Pages: 11-24

11

CHAPTER 2:

Preparing to Comment

A

common approach to commenting is to get a copy of the document,

read it, make notes, and write up comments.

is is a big mistake.

Using this method, there is almost never enough time for review. Com-

ments on a ny g iven docu ment are a lways subject to deadlines, and these

deadlines, which may be set by internal pressures, a scheduled event, or law,

are often tight. For exa mple, there may be as few as 30 days to comment on

the supporting analysis and proposed cleanup plan for a Superfund site.1

Often, you will have less time than expected because it wi ll take a while for

you actually to get a copy of the document or someone may need to comment

on your comments before you send them in. Or you may be busy with other

work or have a personal life. In short, without preparation, you may have to

scramble to review a thick or complicated document in very little time.

Unless you prepare in advance, you may also lose or fail to max imize

your opportunities to coordinate your comments with others. As discussed

throughout this book, you can strengthen your position by encouraging

federal, state, or local agencies or like-minded individuals, groups, organi-

zations, or businesses to prepare comments or to endorse your comments.

Coordination takes eort and time, which you may not have if you are strug-

gling to write your own comments.

Before you even have a copy of the document, you can take several steps to

set the stage and prepare for your review. is chapter provides a step-by-step

guide on how to plan for and organize your work, how to identify and collect

background material you might need, how to use the background material,

and how to prepare a checklist for your review. It may look daunting. You do

not have to do it all. But remember: ere is a good chance that those on the

other side of your issue are doing it.

1 National Oil and Hazardous Substances Pollution Contingency Plan, 40 C.F.R. §300.430(f)(ii)(3)

(C) (2012).