Click here to go to the Federal Register and make your comment to the EPA. Look for the button at the top right hand corner that says, “Submit a formal comment.”
IMPORTANT: The form asks for an organization name. Put your own name in the field. We are all entitled to comment. You do not have to belong to an agency or organization.
- Read ALERT’s condensed version of the most significant changes by clicking here.
- Write your opinions in a letter to the EPA, or use our sample language below.
- Submit your comments to the Federal Register online by clicking here. You will see a button on the upper right hand portion of the page that says “Submit a formal comment.” All comments are viewable, but you have the option of making your name private.
For your convenience, we are providing some sample language for comments on the National Contingency Plan for oil spills. Customize it or feel free to copy and paste it directly.
This comment is in regard to the proposed revisions to the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Human and environmental health are critical issues during oil spills, and we must address the hazards of dispersants and other chemical and biological agents used to “clean up.” We need to specifically:
- Have the right people in charge of decision-making — A) Clarify that the EPA has ultimate authority on product use, not the Coast Guard or the spiller B) Leave local people in charge of developing Area Contingency Plans to bring local knowledge into the planning process and C) Don’t put the spiller in charge of environmental monitoring of spill impacts!
- Expand the scope of Area Contingency Plans to include protection of public health and welfare, as well as wildlife.
- Create more Area Committees with companion Citizens’ Advisory Councils to protect communities at risk from oil activities.
- Use only non-toxic products that will do no more harm during oil spill response.
- Close the loopholes that negate the planning process.
- Establish general listing and testing and monitoring requirements for all agents and certain sorbents as a basic right-to-know if the product is non-toxic and effective.
- Require site-specific monitoring and testing to determine if the product might work as intended and if the product did work as intended during and after use.
- Reduce risk to the environment and people by ensuring readiness of quality products, recovering products from the environment, and timely notification of product use.
- Establish a public process for appeals and removal of products that don’t work as intended, and for transitioning to the new rules.
- Clarify definitions to ensure that we understand what we are dealing with and can plan to mitigate harm from oil and products.