Environmental Review Cheat Sheet Photograph Attribution: By Hariadhi, myself - Own work, CC BY 2.5, https://commons.wikimedia.org/w/index.php?curid=2206309
One of our new reviewers exclaimed - “It’s not so easy!” and asked - “How do I do it?”. The answer is - it frequently comes down to painstaking attention to detail.
Here’s a checklist with tips guaranteed to provide very thorough and hard-hitting technical comments (it also describes our workflow process and the roles of reviewers), where applicable.
Here’s our cheat sheet!:
1. Spotting a document to review: It helps to screen several documents before selecting one for review. Spotting a single error in a document is a strong indicator that the document may have other errors which make for good comments. This website features directories of public comments for the state and federal level which are useful for finding some of the larger projects for review. Those documents can be a little daunting for beginners so it's also a good idea to search city and county websites for smaller projects which are open for public consultation (you'd have to google those local agencies to find those searchable "calendars of public comment periods" + <name of city or county>". When you're searching, a key thing to look for is the "Comments Due Date".
2. Kicking off a review: Once you spot a project/document to review, notify the Review Coordinator (Tom Price at This email address is being protected from spambots. You need JavaScript enabled to view it.). In the email, please include the following information in the subject line: "Candidate Document for Review, <insert type of document, e.g. National Pollution Elimination System "NPDES", Draft Environmental Impact "EIR" Report, Proposed Rulemaking, ...>, <insert location>, <insert regulatory oversight agency name>, <insert comments due date>. We usually pick a review which affords us 2-3 weeks prior to due date to complete the review. In the body of your email include a link to view the document, or attach the document. Then coordination of a Review Team will occur you will receive a "review kickoff: email to announce the formation of a Review Team, reviewer introductions, instructions for completing the review and tips, descriptions of the workflow process, and roles of the Review Team members.
3. Accessibility of electronic postings: If there are any problems on the governmental agencies' websites with accessibility of documents or the electronic links are bad, or if you have general questions about the public comment period, feel free to email the caseworker with the agency and ask questions. It may be a good idea to ask if the facility has any history of noncompliance .
4. Check the contents of the document: Take a look at the table of contents to see if the document is properly assembled (you may find tables, figures, or references sections are missing, or the contents of appendices may have been left out). Start with a common sense read (or skim) to decide whether or not to conduct a comprehensive review of a document or just target certain topics.
5. Memorize basic data: Figures and tables provide a good place to start a review. Those show us the site layout and apparent problem. We recommend memorization of maps and basic data distributions with an eye to screening values to aid in the review of the text. The importance of memorizing basic site-specific data is emphasized because this practice emulates talented environmental scientists and engineers who possess photographic memories. This practice fosters an aptitude to process data sets in your mind and increase the speed of your reviews.
6. Notice citations to regulations in the introduction: Usually the introduction section cites regulations which the document intends to address. Look those up to see if you agree with the way the writer proposed to meet the requirements of the regulation. You may find that regulatory diligence requirements are given short shrift by the author practicing subtle sidestepping or cutting corners (to save their client money). Many documents are dismissive of the need to consider a meaningful alternatives evaluation to mitigate environmental impacts. You may find that the document advocates for mitigation of environmental impacts by adoption of a presumptive remedy which is less than optimal.
7. Question fieldwork conditions which trigger notification requirements to the regulatory oversight agency during field operations: Frequently, implementation plans are sketchy when it comes to specifying triggering conditions for notifications to the the governmental oversight agency. Larger development plans should specify that the regulatory oversight agency will be notified if contaminated soil (discolored or odorous) or underground storage tanks (USTs) are encountered, but many plans lack this important detail. To address this, requiring weekly reports which document field activities may be a good idea, esp. if mitigation measures should be adaptive (e.g. for dust control, odor control, noise control, confirmation sampling, species monitoring...).
8. Check to see if guidelines are followed: The references section will frequently cite guidelines which provide details on methodology, protocols or standard operating procedures (e.g. data gathering procedures, collection of samples for soil, air, or water, surveys for species...) which you may find the document failed to adequately follow.
9. Laboratory reports are fertile ground for review: Transcription errors from lab sheets to tables are common. Laboratory report narratives frequently identify problems or limitations with the data which should be discussed in the report however, those are commonly overlooked. Laboratory data should be reported on tables using “< (insert detection limit)" not the outdated practice of filling tables with “ND” (non-detected) which does not allow for comparison to screening values. Check to see if the laboratory detection limits are low enough to make a meaningful comparison to environmental screening values or standards. If the detection limit is not low enough, we may suggest the use of a higher performing laboratory method. Many documents fail to have or implement quality assurance project plan or quality assurance/quality control (QA/QC) plan. A quick way to gauge data quality is to check to see if relative percent differences between duplicate samples is within tolerance specified in cleanup plans' data quality objectives (e.g. +/- 20%) or guidance documents. USEPA's National Functional Guidelines provide a great reference for laboratory quality assurance guidance. For laboratory procedures, refer to USEPA's solid waste publication SW-846.
10. Comparison of site data to screening values; Site specific data should be compared to screening values (guidelines) published by agencies or promulgated standards (enforceable standards e.g. drinking water maximum contaminant levels or ambient air quality standards). Comparison of site data to screening values may be useful for range-finding to preliminarily gauge risk to inform the decision as to whether further investigation is needed. USEPA's Regional Screening Levels provide a great reference for comparing site data to screening guidance. USEPA's Data Quality Objectives provides a great reference for an iterative process for developing a clean up plan for a site (collecting data, evaluating data, setting cleanup goals, collecting more data...) which is sophisticated.
11. If additional information is needed: Email the agency caseworker. We generally try to avoid requesting additional information in our comments if that information may be obtained by emailing the agency during the comment period. You can email the caseworker to inquire if historical documents related to the project are available for viewing online or you may request them to email pdf copies to you.
12. Range of technical considerations: Once you understand the intent of the document and the apparent problem, consider strengths, weaknesses, opportunities, and threats (SWOT) the sensitive environmental conditions may present. Consider a sensitivity analysis (what might happen to the mitigation plan if stressors are put on it) or what might go wrong over time. Consider whether the document adequately relies on multiple lines of evidence. Consider whether the document addresses cumulative impacts and natural resources damages. Consider whether chemical or hazardous substances exposure pathways to receptors are complete. Consider whether the document was properly certified by a licensed professional (e.g. geologist or engineer). Consider whether the project approach addresses: overall protection of human health and the environment; compliance with relevant standards of guidelines and regulations; both short and long term effectiveness; reduction in toxicity, mobility, or volume; whether it is implementable; cost alternatives; acceptance by the local regulatory agencies; and acceptance by the local community (those are the nine criteria specified under 40CFR300.430(e)(9), the National Contingency Plan).
13. The best comments to make: Public comments are particularly valuable when they: a) list any inaccuracies, b) show how potential environmental impacts that haven’t been identified by the proposer are present, c) show that certain environmental impacts have been identified but haven’t been adequately addressed, and d) you may suggest possible mitigation measures that should be added to the document.
14. Roles of the Review Team members: Most Review Teams are comprised of two reviewers, a Senior Reviewer and an Environmental Reviewer. However we may add additional members to the team as needed or if someone wants to join a team. The Senior Reviewer's review may range from cursory proofreading to a comprehensive review (including adding comments) depending on how much time they have available to contribute. The Senior Reviewers' role is to review the document, provide direction to the Environmental Reviewer(s) for commenting topics, editing, and approving of the comments. The Environmental Reviewer's role includes interfacing with the agency and following up for additional information if needed, conducting a review, drafting comments, researching topics for commenting under the direction of the Senior Reviewer, seeking the approval of comments by the Senior Reviewer, and submitting the comments to the agency which is hosting the public comment period.
15. Education and Senior Reviewers' method for leading and drawing out comments: During a review, we are focused on guiding our volunteers achieve their highest potential as environmental reviewers. We are rolling out an educational pilot based on the word root for education, “educere" which means “to lead” and “to draw out” (from Latin). For each review, the Sr. Reviewer may lead by identifying topics which are considered viable for commenting. The Sr. Reviewer leads the review by providing the Environmental Reviewer with direction and request preparation of comments for those topics which are considered viable (in addition to their own comments). After the Environmental Reviewer prepares draft comments on the viable topics, those are returned to the Sr. Reviewer for markup (we suggest that the markups should draw out comments from the Environmental Reviewer by providing edits halfway toward a final version of the comment). Those markups are provided to the Environmental Reviewer for finalization. In this manner, we hope to provide the Environmental Reviewer with professional direction and draw out the comments from them to enhance their learning experience. After the Sr. Reviewers approves the final version, the Environmental Reviewer is tasked with sending the comments to the agency. Senior Reviewers, in their interactions with our Environmental Reviewers may also the educational component of our mission as a nonprofit public benefit corporation by mentoring and providing feedback on performance, and may suggest reading materials for self-study, seminars to attend, and pursuit of higher education.
16. Timeframe for the Review Team: We need at least 2-3 weeks to work on a review and getting draft comments to the Senior Reviewer a week or at least half a week prior to the due date is typical; providing comments the last day before the comments are due may likely result in proofreading only.
17. Collaborative commenting by the Review Team: We try to adapt the number of review rounds on a case-by-case basis. Ideally, multiple rounds of reviews may be completed with the Senior Reviewer providing a "redline edits" version(s) which is most instructive for educational purposes. In order to achieve a fully collaborative review, we encourage the Environmental Reviewer(s) to ask questions, request direction on topics to research and comment on, and ask for tips that will result in an impactful review. In like manner, we encourage the Senior Reviewer to answer questions, provide direction, suggest topics to research and comment on, and provide tips that will result in an impactful review. When a fully collaborative review is achieved, the likelihood that the comments may result in enhanced environmental protection is increased.
18. Communications by the Review Team: During the course of a review, typically communication occurs by email correspondence since that is most efficient. However, we're flexible - it may occur by telephone, videoconferencing, in person meetings, or through co-editing on our document management on the cloud if preferred or possible.
19. Specificity of comments and posing questions: We make our comments as specific as possible (e.g. by citing the page number, section number, paragraph number, and sentence number) and pose our comments in the form of a suggestion for improvement or correction in order to elicit responses from the agency (i.e. we avoid posing our comments in the form of general statements that the agency can ignore). Some agencies do not consider questions to be comments, and encourage commenters to email the agency to ask questions, not ask questions during the public comment period.
20. Final Editing by the Senior Reviewer: If the schedule is tight, the Senior Reviewer may finalize a set of comments in a single round of review and provide an edited "Final" version with instructions to "Send" or a "Draft Final" version with instructions on how to "Fix and Send". The Senior Reviewer may delete some or all of the comments if they are not considered significant enough to submit to the agency (in order to avoid submittal of frivolous comments). In the final version, the Senior Environmental Reviewer is encouraged to not hold back, to provide substantive and hard-hitting technical comments, and to give the comments a professional touch. The comments should be technical, professional, and polite.
21. Letter format of our comments: The letter format provides valuable context for readers of our comments on our website. So we use the letter format for our comments with the date, contact person, agency name, address at the top, a salutation, opening sentence (e.g. "Environmental Review, Inc. has reviewed the document <insert review document title, facility name, location, and comments due date>) and has the following comments: <insert numbered comments>". And we close with a signature block of e.g.: <insert complementary closing>, <insert name of Environmental Reviewer> (Associate in <insert state>), Environmental Reviewer, Environmental Review, Inc., 1792 Rogers Ave, San Jose, California 95112 www.envreview.org, (a 501(c)(3) Nonprofit Public Benefit Corporation). If you would prefer to use an alternate signature block (e.g. a personal or business signature block), we're flexible. Or if you would prefer to not have your name on it, let us know, we can submit the comments for you.
22. Approval of comments and sending to the agency: Once the Senior Reviewer provides final edits and approves the comments, the Environmental Reviewer sends the comments to the governmental agency which is hosting the public comment period via email or by posting the comments on an electronic submittal page with the governmental agency (it's usually a good idea to follow up to confirm receipt).
23. Posting the comments on our website: Finally, the Environmental Reviewer will post the comments which have been submitted onto our website as an article of their portfolio (entitled "<insert date in format MM-DD-YY>, Comments Provided to <insert agency name> on the <insert title of comment topic>, <insert location>". You will be given a username and password to post the comments as an article onto our website. After you log on, navigate to the state agency (or federal if the projects spans more than one state). The easiest way to post your comments by copying and pasting from a Word document. After you post your comments, we suggest adding two features for the benefit of your readers: 1) photograph(s), and 2) Introduction section to share background information about the project and regulatory environment that is usually not included in the comments. Add a photograph at the top of the article with a caption. Wikipedia is a good place to find public domain photographs which are readily available for use with appropriate attribution to the photographer or artist. A second photograph midway through the article (esp. of species) can also enhance your article. Add an "Introduction" section to your article for the benefit of readers of your article; this style was developed by Matthew Coughlin-Environmental Reviewer, for his example see: http://www.envreview.org/
24. Context and style of our comments: Citations to publications should be italicized. Acronyms should be defined and placed in parentheses for the first usage. Comments should provide enough context (from the document under review) to be understandable without requiring the reader to refer to the document (e.g. referring to mitigation alternatives by number does not help the reader, so the scope of cited alternatives should be described). To aid the reader, use active verbs in shorter sentences. Avoid using passive verbs. Bulleted lists help the reader. Starting a sentence with the word "Since..." is great for making a quasi "if-then" comment. Starting a sentence with the word "Therefore..." is great for finishing a comment after you've laid a foundation. Use of the imperative voice lends strength to comments (e.g. "Since the figure is missing, add that." Using the phrase "at up to <insert highest chemical concentration detected at the site>" provides a high level summary of site data (e.g "Arsenic was detected in soil at up to 500 milligrams per kilogram at the site." We use pronouns sparingly and check to see that the noun pointed to is clear. Ending a sentence with a noun lends itself well for starting the next sentence with a pronoun that points back to that noun because since the words are so close together on the page, there is no question which noun the pronoun points to. We use bolding and underlining sparingly because it may distract the reader from the content. If you need to emphasize a word or phrase, use italics. For more on style see The Elements of Style by Strunk and White.