RE: Adequate time for public review

[Glenn Landers <glenn.landers@sierraclub.org>]

Most people I know who work on permits would recommend that you begin reviewing the application as soon as it deemed complete, since this document forms the basis for the terms and conditions that will show up in the permit.

I think you are absolutely right, early access to information is essential. 

Related issues:

I don't know if this happens on the federal level, but with the state of Ohio you can have a situation where a draft permit is issued for comment, but not all the background documents are available because of confidentiality claims. But, by the time the state responds to a request for a determination of confidentiality, the comment period will be long over. 

I've also seen situations where Ohio has opened a comment period, but the file for the facility was not locally available.  It took several days to get it shipped.

Some regional offices of Ohio EPA ask for a week or more notice from citizen's to do a file review. In a thirty day comment period, that's a huge barrier.


Failure to provide basic information, or timely access to it, should stay the action.