Improve input to permitting

[Ron Anzalone <ranzalone@achp.gov>]

My name is Ron Anzalone, and I'm with the Advisory Council on Historic Preservation.  We are an independent Federal agency charged with overseeing historic preservation review under the National Historic Preservation Act.

The comments on improving input are on the right track, but there's some dancing around the major issues.  There are three  bottom lines, in my opinion:  first, get enough information out--but in as understandable (and simple) a form as possible so that people will understand what a permit, if granted, would allow, and how they can influence the decision should they choose to.  Second, get that information to, and actively seek input from, the people who are most interested in, concerned about, or knowledgeable about, the permitted activity, so that their views could be considered by the applicant, the permitting authority, and other involved parties.  Third, try to ensure that the permitting authority and the applicant explicitly acknowledge how this permit fits in with other actions--other permits, other approvals, land-use changes, necessary timing, etc.  Permit notifications are often so isolated from the rest of what's going on that the public may not catch on to the big picture until late in the game, and this sometimes spells real trouble for all concerned.    

The discussion to date has largely been about process, but everyone needs to keep in mind that the ultimate goal of process should be a series of tangible results--community health, clean(er) air and water, protected natural and cultural resources, reasonable and prudent operations that meet various standards, etc.

So to return to Charlie Atherton's list--think about what really needs to be there, what needs to be highlighted, and how would you help folks understand the consequences of issuing, not issuing, or conditioning a permit?  What other Federal or State actions might come into play--is there a Corps permit in addition to the air or water quality certification?  We also need to distinguish established, long-term operating facilities (plant tours, etc. have been suggested) vs. more immediate, one-shot construction and discharge actions.

Ron Anzalone