Writing Your Comments

The best way to get started on the commenting process is to read through some of the sample comments provided to get a feel for some of the key issues. Then, look at the permit and accompanying fact sheet that the DEQ has provided. Every proposed NPDES permit will be accompanied by a Fact Sheet that explains permit characteristics, monitoring and considerations in less technical terms. This document can often lead you to some of the key issues to investigate further. With the proposed permit in hand, compare to Oregon's Water Quality Standards.

The format of written comments can be important. They should be clear and concise, and can ask specific questions. In making a decision, the agency will address public comments received and specific questions require specific answers. This dialogue can prove helpful in understanding and more accurately challenging discrepancies and water quality threats. In addition, there is nothing wrong with commending the agency and/or facility for innovative technologies, upgrades and improvements. In the same vein, suggesting new methods of wastewater treatment used elsewhere can also provide useful feedback.

Important questions to consider in your first glance at permit documents:

• What impact could the discharge have on existing uses of the area?
• Does the receiving waterbody already have water quality issues?
• Is the discharge from the facility increasing?
• Are the effluent limits in the permit increasing from the previous permit?
• Do effluent limits follow Oregon’s Water Quality Standards?
• Has the monitoring strategy changed?
• What pollutants are discharged and what concerns do those pollutants raise?
• Does the facility have a history of non-compliance?

Take notes on issues that raise concerns and feel free to contact the agency with questions. You may also request a formal public hearing if there are important issues. The Clean Water Act gives citizens the right to request such a hearing. Public hearings can be useful to bring community members together to discuss water quality issues in the area and to notify the DEQ of your concerns.