Developing Comments
Be Brief and Objective: State your opinion in a straightforward and objective manner. Your comment will become part of the public record.
Identify your Experience, if applicable: If you are commenting in your capacity as a professional (scientist, engineer, attorney, doctor, elected official, etc.), or as an official representative for an organization, say so. Provide a brief overview of your organization, its size, and its interest in the matter.
Be Polite and Respectful: As a general rule, the tone of the comments should respectful. Those reviewing comments are public servants tasked with a job, and they deserve the same respect and professional treatment that you and other citizens expect in return.
Be Specific and Relevant: Your comments should relate to the pipeline facility/activity being permitted and you should state clearly the reason for your position. General comments that state an action will have “significant environmental effects” will not help an agency make a better decision unless the relevant causes and environmental effects are explained. Comments are most effective when you explain how they relate to the requirements that apply to the facility. Include a citation or a quote of the specific text or regulation you are referring to. Typical comments that may require further review and consideration of the permit application include:
- Applying the wrong standards or regulations.
- Making errors in the data or calculations. Cite reference materials to support your position.
- Using improper methodology, calculations, and/or analysis.
- Failing to comply with other State, Federal, or local regulations.
Identify Solutions and Alternatives: Comments that are solution-oriented and provide specific examples will be more effective than those that simply oppose the proposed project. Comments that contribute to developing alternatives that address the purpose and need for the action are also effective.
General Guidelines
Citizen involvement is critical to protecting Michigan’s water resources. It is important that you take this role seriously and participate with integrity. Even though you may feel like the “deck is stacked against you,” following certain guidelines will ensure that public participation is given the respect that it deserves. Although each of us go about protecting water resources in our own way, these general guidelines help ensure that public participation is taken seriously:
- Base your position on solid technical information and sound policy analysis.
- Gather information in legal ways.
- Respect the legal rights of others, including the agency staff and the applicant.
- Don’t use water resource protection as a “red herring” to further other goals that have nothing to do with water resources.
- Raise issues with the agency should do so at the earliest possible stage in the process. Agencies are much more likely to evaluate a new alternative or address a concern if it is raised in a timely manner.
- Remember that commenting is not a form of “voting” on an alternative. The number of negative comments an agency receives does not prevent an action from moving forward.
- Similarly, numerous comments that repeat the same basic message of support or opposition will typically be responded to collectively. It is best to provide individual comments than submit a form letter.
- Continually work to improve and expand your knowledge of pipelines and the regulations that govern them.
Local Permits
Local permits are generally applied for and acquired during the initial phase of a pipeline construction project. Many city and counties, especially in the more urban areas, have planning departments that regulate most types of construction. New construction projects must undergo a filing and approval process before a planning commission or zoning board. Check with your local municipality if there is a pipeline project proposed in your community
