RE: Adequate time for review - thoughts needed

[Monty Elder <monty.elder@deq.state.ok.us>]

In Oklahoma we have a uniform permitting process across media, the level of public involvement mandated by the process depends upon the complexity of the permit.  For significant permits, like PSD air permits, NPDES (in Oklahoma it is delegated so it is actually OPDES), or RCRA permits, there is an up front step called a Process Meeting.  This meeting occurs within 30 days of the original filing of the application.  It is noticed in the newspaper and held in a public place near the site of the application.  The purpose of the meeting is to lay out ahead of time the entire permitting process for the public.  We go over what is an application, where can you get a copy locally, what will DEQ be doing to prepare a draft permit, public review and comment opportunities including timelines, access and public meetings, response to comments, proposed permits, how to request administrative hearings and timelines, and final resolutions of permit.  In this way, people know ahead of time how to get a draft permit, what the comment period will be, and how to make comments.  The comment period is 30 days, but we will extend that upon request from the public.  This has worked well for DEQ and citizens, especially when there is interest in the permit application up front.  I have conducted several process meetings in which over 100 people were in attendance.  We also have an open question and answer period with the meeting.  Everyone at the meeting is included in the mailing list and gets updates on the permit every 4 to 6 weeks and gets notices of all milestones like draft permit issuance, public meeting schedules, etc.  Another important aspect of our outreach is that we have a 1-800 number that people can call anytime for information.  I believe this is vitally important - our office is in Oklahoma City and obviously, there are lots of facilities across the state with permits.  I can say that we are available to answers questions but if it costs anything, even $1, to reach us then we are not truly available.  I would encourage every permitting agency to have such an 800 number and also to put in these process meetings up front in the permitting process.  This does work best when there is interest up front.  I still struggle when there appears to be little or no interest when the application is announced.  Certainly it is much more difficult for citizens to be involved when they come into the process somewhere in the middle.  The key is to make sure people who will be potentially impacted by the permit have information about the permit, potential for impacts, and process as soon as the application starts through the system - but sometimes we don't seem to do a good job of generating the interest early in the process.  I am enjoying reading all the comments which give suggestions on this.  Thanks  Monty Elder, Oklahoma Department of Environmental Quality