ELI Skills Seminar: Making the Most of Agency Requests for Comments

When
December 10, 2013 11:27 am — 11:27 am
Where
Webinar only

This online workshop trained attorneys and environmental professionals to further advocate for their clients by writing effective comments on agency rulemakings and guidance. While the workshop used the Environmental Protection Agency (EPA) as a model, faculty also showed how skills acquired for the EPA are useful for submitting comments to a variety of federal, state, and local government bodies on everything from environmental impact statements to legislative bills.

Myriad entities have a stake in how the written documents implementing environmental laws are worded. Companies, organizations, and individuals can all influence how draft regulations, policies, programs, plans, studies, reports, and permits are worded by taking advantage of commenting periods and calls for comments on drafts. This workshop taught best practices for how to most effectively argue your clients’ position before environmental agencies through written comments.

This session’s faculty had decades of experience in the federal government, NGOs and private practice and shared a balance of perspectives on vital issues such as how agencies process and "hear" comments; how to manage clients’ expectations about commenting; and how practitioners can best work with agencies to achieve the desired results.

Skills Taught

  • Steps to take to plan, research and strategize when preparing comments.
  • How to organize your comments, what to say in them, and how to say it.
  • How to work with agencies and follow-up once your comments have been submitted.
  • Legal issues around public commenting on agency documents.

Faculty:
Grant B. MacIntyre, Associate, Bracewell & Giuliani LLP
Elizabeth D. Mullin, former Executive Director, Rock Creek Conservancy

Suggested Further Reading
The Art of Commenting