RE: State roles in public participation

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

Yes, for some type of programs, it will show up in the next audit. In Ohio, it'll probably even show up in the next ten audits. 

There are also submissions a state has to make, for instance the list of waters that require a TMDL, where I think there is just a check list. The state just describes the public process it used to develop the submission.

The trick for the state is to stay below the high threshold that would cause the EPA to act.  There is, practically speaking, no danger of EPA taking over a permit program because there are lots of mistakes or inconveniences in the public comment process. 

Nor is there much danger that a state's submission of a plan might be rejected because they shorted the comment period by a couple days in order to meet a federal deadline.

You are lucky if your state does it right. And, I can tell you, I sure wouldn't want to be the Ohio EPA person who has to blow the public off. It's never the person who made the decision that has to catch the heat from the public.