10 tips for making effective public comments

Thank you for your interest in submitting comments to the Air Pollution Control Division. To protect public health and improve Colorado’s air quality, the division may present rules, permits, guidance documents, and/or other updates to communities so they can share their feedback and ask questions. 

Please consider the following tips for effective public comments. These tips are for written comments but can also be helpful when planning oral comments for a public meeting.

We acknowledge that not everyone has the time, resources, and expertise to apply each of the tips below. Our team values and considers every comment we receive, even in instances where the division may be limited in the changes it can make. Using the tips below – to the extent that you are able to – helps ensure any comments you provide are most effective and meaningful. This way, we can best use the information you provide to inform decisions and protect clean air.

Questions? Email us at cdphe.commentsapcd@state.co.us.

1. Read before you write. Familiarize yourself with the scope of the issue and review background information related to the particular issue you would like to provide comment on. Jot down what you hope to see and any major concerns you have.

2. Start your comment with your specific request(s) or feedback. Are you trying to start, stop, or delay a particular action? Correct possible errors or data gaps? Ensure a decision is in line with your organization’s policies or community’s needs? Support or oppose a rulemaking? Think through your key requests and state your opinion or requested action up front to help us best understand your position. 

3. Make sure we can act on your comment. We accept all comments. However, we can only make changes that are in line with the division’s scope and legal authorities. The changes must also be applicable to the proposal's requirements. We cannot grant exceptions to state or federal regulations. Please focus on the information that we can act on. 

4. Be specific. Identify the distinct parts you think should be changed or the parts you support.  We encourage you to suggest specific wording changes. If you think we missed something in the analysis or in a certain section, explain what additional information or concepts you'd like us to include. Provide concrete examples of your concern, either real or hypothetical, where you can.

5. Offer creative solutions. If you think a concern or challenge can be better addressed in a different way, let us know! We welcome your suggestions on how we can solve a problem. Alternative ideas can help strengthen our actions. 

6. Keep your comments clear and concise. Try to include only what must be said to accomplish your purpose. Avoid repeating your points. Consider using headings and subheadings to separate your points. If you have more than one major concern, consider opening your comments with a summary section and outlining them before you give details.

7. Be careful using form letters or mass email. Before you use any pre-drafted comment letter, review it to see if it follows these tips for effective comments. If it doesn't, write your own. The comment process is not a vote, and it’s important to note that mass emails may get caught in a spam filter. A single, well-supported comment may carry more weight than a thousand comments that say the same thing without supporting evidence.

8. State why this topic or issue matters to you. Do you live in a community that will be directly impacted by this decision or proposal? Share your connection to the topic or issue, your lived experience, personal background, and unique insights. This could include disproportionate pollution impacts in a community that you or people you know have experienced. It may help us better understand the challenges and opportunities related to this decision and the factors we should take into account.

9. Share relevant data. Are you aware of a study or article directly related to this topic? Cite or share that information in your comment. We strive to incorporate the best available science and information in our decisions.

10. Stay connected. Explore additional opportunities to provide feedback throughout the rule, permit, or guidance document development process. There are often multiple ways and times for you to provide feedback over a period of months or even years. Stay up-to-date by visiting our public participation website, signing up for email updates, and following the Air Pollution Control Division and Colorado Department of Public Health and Environment on social media. Send comments or questions to: cdphe.commentsapcd@state.co.us.

To demonstrate the suggestions above, below are some examples of very helpful vs. less constructive comments. 

Example 1 of a very helpful comment: “Condition 10 talks about monitoring startups, shutdowns and malfunctions but does not say how these need to be tracked. The proposal should include specific monitoring requirements. Additionally, Condition 15 says that the operators must notify the division promptly of any malfunctions but there is no definition of what promptly means. The proposal should specify a number of days rather than use the word “promptly.”

Example 2 of a very helpful comment: “The proposal identifies emission sources and mentions "co-benefits," but it doesn't define or explain what a co-benefit is or how it helps improve air quality. Please include a definition and description of “co-benefit” in the proposal so members of the community can gain a better understanding of the benefits they can expect to see..”
 

Why they are very helpful comments: These comments are easy to understand and act on. They offer solutions and the suggested changes align with Colorado state regulations, so we are able to make them. 

Example of a less constructive comment: “Emissions from industrial operations are bad for the environment and public health, and you should not be allowing them to pollute like this. This proposed rulemaking should not be approved.” 
Why it’s a less constructive comment: This comment is welcome, but it does not provide specific information we can act on. 

Thank you again for your interest in partnering with us for a cleaner, healthier Colorado!