I. Introduction to What We Do: We review and comment on environmental documents which are posted online by governmental agencies for public comment periods. That way we provide public oversight for protection of human health and the environment. Since we identified that there is a need for public commenting where stakeholders are absent, uninterested or unable to comment due to the technical nature of the work, our goal is to fill that need on the project level when we provide comments. The type of projects we are interested involve air quality, air pollution, water quality, water pollution, soil contamination, hazardous waste disposal, protection of endangered species, developments plans with environmental concerns and so forth. We comment at critical points, during the public review stage for cleanup plans, permitting processes, periodic reviews or development plans for environmentally sensitive projects.
I1. Classification of Volunteers: We have three classifications for volunteer positions: Senior Reviewer, Reviewer, and Review Coordinator. The classification that each volunteer starts at depends on the level of education and experience. Senior Reviewers may comment independently or sponsor collaborative reviews for the other volunteer classifications.
III. Deciding What Type of Project to Review: A strong aspects of our program is each volunteer gets to choose what types of projects to review. That allows for self-directed professional development to those new to the field or allows seasoned professionals to focus on their area of expertise. When deciding which project to select for a review, you should assess what interests you the most, where you want your career to go in the environmental field, what your education or experience are, and what you are most passionate about for environmentalism. Other things to consider include the strengths of your team, for example you might consider focusing on the area of expertise of the Senior Reviewer on your team in order to learn by their example. You need to decide if you want to become involved with local, regional or national issues and select projects accordingly. Another thing to consider when screening documents for review is whether you can identify something to comment on because identifying a single initial inconsistency in a document is a good indicator that the document may contain other inconsistencies (forensic science approach) which may lead to an impactful review.
IV. Our Directories of Public Comment Periods: The first task assigned to our new volunteers is to find a project to review. To do that you can utilize our directories of current public comments periods for environmentally sensitive projects. Our current focus is projects on the state and federal levels and our directories reflect that emphasis by showing links to current public comment periods for all 50 states and selected federal agencies. Usually the agencies will publish electronic notices on their websites that announce that public comment periods are open, include the deadline for providing comments, and show links to documents which are available for review. The reason that the governmental agencies post these notices is to fulfill public participation requirements associated with environmental regulations. We also encourage our reviewers to review city and county projects which are open for public consultation; to find those, you'd have to google the local agencies or public works departments and a key thing to look for is "Comments Due Date". Local newspapers are great for spotting local projects you may be most interested in commenting on! Once you have found a project to review, send us a link to the document to the Program Manager (Tom Price at This email address is being protected from spambots. You need JavaScript enabled to view it.) to confirm it is suitable for a review. Usually we look for projects which allow us at least 2-3 weeks to conduct a review before the comments' due date.
V. Our Document Management System: We use ONLYOFFICE, a document management system which also features our staff directory. Our workflow process is to set up a project, enter a project description, assign participants, upload project documents for review, and create a document of draft comments to which all participants can provide edits. The project also shows profiles of team members that are involved in the review including photographs which help us with teambuilding since we have a decentralized organizational structure.
VI. Our Collaborative Review Process: A typical review will involve three collaborators, a Senior Reviewer and an Reviewer and a Review Coordinator to manage the review. Once a suitable public comment period and document is selected, the Review Coordinator will assemble a Review Team and send an "environmental review kickoff" email to all participants. Then comes the work of reviewing the document and all collaborators may provide input to the document. A Senior Reviewer may conduct a full review or only provide final proofreading and edits and approval for the send out. The Senior Reviewer may guide the review by suggesting commenting topics which have been identified as viable. The Review Coordinator may host videoconference meetings over the course of the review. Once the due date for the comments approaches, the Senior Reviewer provides final edits to the document, deletes non-impactful comments, and gives the Reviewer approval to send out the comments to the governmental agency which is hosting the public comment period.
VII. Our Technical Review Process: We try to give each document that we review a “common sense reading”, in other words, whether or not it would be understandable to a layman. If it would be hard to understand for a layman, that may indicate that the document should include clarifications or worse that it may contain technical deficiencies. We review documents for technical adequacy, consistency with regulations and guidelines, and completeness. Usually documents cite regulations and guidelines in the introduction or references sections. We look those up and compare our technical interpretation of what those say to how the document interprets them. Discrepancies between the two usually provide the basis for many of our comments. The level of review is variable because of the wide variety of guidance documents relevant to any particular project on the state and federal levels (e.g. data quality objectives, quality assurance project plans, risk assessment guidance, applicable, appropriate and relevant requirements...). To see our detailed review checklist see: http://www.envreview.org/index.php/educational-articles/219-cheat-sheet-for-environmental-reviews-12-13-20
VIII. What We Do After We Prepare Comments: After the comments have been prepared and approved by the Senior Reviewer, the comments are typically sent by the Reviewer to the governmental agency via email. Sometimes we ask for confirmation from the agency that the document was received in a follow-up email. When uploading comments to our website, you may copy and paste from the original Word document (this seems best to avoid tricky formatting from emails) or by copying the comments from their sent email box and paste those as an article on our website. The title format is: “<insert date>", Comments Provided To" <insert agency name>, <insert project name, location>”. Then the article is published by our website administrator. In this manner, we provide useful information to the governmental agencies for improvement of project performance for protection of human health and the environment. And after the comments are published on our website for public viewing, we also increase awareness of environmentally sensitive issues for visitors of our website.
IX. Obtaining Responses to Our Comments from Governmental Agencies: A challenge we face is getting responses to our comments. Once the comment period has ended and the governmental agency has prepared responses to our comments, we may obtain those via email (as we request with our comments) or by following up with the environmental agency's representative for the project, or by viewing those when they are published on the agency website. The responses we obtain from the agencies are then pasted into the top of the original comments' article and the title is updated to "<insert date>, Response to Comments Provided by <,insert agency name>, <insert project name>".