The types and amounts of public comments seen in recent permit actions in Louisiana have increased as well as changed in nature in the past several years. Comments are much more lengthy, detailed, and technical. In the past, comments were typically submitted by near neighbors as well as local environmental groups. Comments are now being submitted by a more diverse population both geographically (statewide as opposed to south of interstate 10) and demographically. This increases the time to receive a permit as the agency has to respond to each public comment and the final responses have to be reviewed by legal personnel in the agency. To minimize agency permitting times and meet construction schedules, companies must proactively include information in the application to reduce comments or information which helps the agency to respond adequately to these comments. Permittees must also consider going above and beyond the regulatory requirements both to pre-empt comments and to receive permits in a timely manner. This presentation will provide examples of comments which have been submitted on recent draft air permits (for both greenfield and existing facilities) and the agency response. The presentation will also suggest strategies to minimize permit time and receive a workable permit.
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