Category: Public Comments

Making Effective Public Comments to DEQ

Different kinds of agency decisions call for different approaches for making effective comments. The most effective comments have one of two primary elements in common: they request actions the agency has legal authority to make, or they provide new information the agency has not yet considered.

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Frequently Asked Questions
Public Notice and Comment Process

Update Starting May 8, 2012 public comment will be a prerequisite to challenging permitting decisions. Under Section 19-1-301.5, effective May 8, 2012, a person who wishes to challenge an Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient …

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Utah Environmental Law and Standards

Utah environmental legal requirements are generally found in three places: Utah Statutes | Utah Rules | Licenses and Permits Utah Statutes Statutes are laws passed by the Utah Legislature and, usually, signed by the Governor. Utah statutes usually provide general guidance about control of pollutants and about how DEQ should implement a program. The activities …

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Making Effective Comments About Proposed Permits and Licenses

If an application meets all legal requirements, DEQ is required to issue a license or permit. For that reason, most effective comments have one of two primary elements in common: they request actions the agency has the legal authority to make; or, they provide new information the agency has not yet considered. A review of …

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Making Effective Comments on Proposed Rules

It may be helpful when commenting on a proposed rule to consider the agency’s authority to make the rule. Most environmental statutes authorize one of DEQ’s boards to make rules; the boards have only the authority given to them in that statute. The Utah Drinking Water Board, for example, has these authorities: (1) The board …

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Making Effective Comments about Settlement of a Violation

Most DEQ agencies have an enforcement or penalty policy that guides its decisions about settling a violation. Reviewing the relevant policy would help a commenter focus on those matters that an agency will ordinarily consider. Statute Penalty Policy Air Conservation Act Utah Admin. Code R307-130 Air Conservation—Federal Asbestos Hazard Enforcement Utah Admin. Code R307-135 Drinking …

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DEQ: Tips for Making Public Comments Count

By Donna Kemp Spangler I understand people’s frustrations when they take the time to submit a written or verbal public comment on a regulatory proposal and at the end of the process, the final rule or regulation doesn’t seem to reflect their comment. They walk away with a feeling their comment doesn’t really matter. That’s …

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