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Making the Most of Agency Requests for Comments (ELI Skills Seminar)


April 29, 2015



An ELI Skills Seminar – CLE Credit Available!

This online workshop trained attorneys and environmental professionals to advocate for their clients by writing effective comments on agency rulemakings and guidance. Faculty taught the skills required for the submission of effective and persuasive comments to a variety of federal, state, and local government bodies on everything from environmental impact statements to rulemaking.

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 to taught the best practices for how to most effectively argue your clients’ position before environmental agencies through written comments.

This session’s faculty has decades of experience in the federal government, and private practice to share 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 desired results.

Skills Learned:

  • How to plan, research and strategize when preparing comments.
  • How to organize 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.

Benefits of Participating Early and Often:

  • This was an interactive webinar. Participants were encouraged to send suggestions for topics to be discussed and questions that they wanted answered by our panel before and during the webinar.

Carrie Wehling
, Attorney-Advisor, Office of General Counsel, USEPA
Daniel Schulson, Associate, Beveridge & Diamond, P.C.

Suggested Further Reading: The Art of Commenting (to get 15% off the list price of the volume, ELI members should contact mcmurrin@eli.org for their coupon code)

The materials from this event are made available only to registered participants. Registrants may access the files at the bottom of this page after logging on to their ELI accounts. [If you forget your password, click on the Reset Password button.] Problems?: contact mcmurrin@eli.org


To receive CLE credit:

  • You need to register for the webinar and provide payment to ELI prior to any applicable CLE deadline for your jurisdiction.
  • If you desire CLE credit in a jurisdiction that we list as having pre-approved the session, you must still note on your webinar registration that you want CLE from that jurisdiction.
  • You will need to actively respond to several polls that are presented during the live session. This means that you must be logged into the webinar and able to participate when the session begins at 12 noon ET and for the entire duration of the session.
  • You will also need to complete an online survey. Your certificate of attendance will be emailed to you a week or so after the session.

To find out about the status of CLE approval in your jurisdiction:

View our Event Policies (incl. substitutions, cancellations and refunds)
View our Financial Hardship Policy