How to Make an Effective Public Comment

Whether you’re ready to submit a written comment or state your case at a hearing, these talking points, scripting guidelines, and other tips will help you make the most of your airtime.

Gabrielle Habeeb speaking at a public hearing in Chicago, Illinois

NRDC forest advocate Gabrielle Habeeb speaking at a hearing on the affordable clean energy proposal at the Ralph Metcalfe Federal Building in Chicago

Credit:

Alyssa Schukar for NRDC

Virtual public hearings are now the norm for agencies gathering community input at every level of government, from federal down to local. These, together with online comment periods, are places to share input on rules and standards that can have a huge impact on issues you care about—from drinking water protections to air pollution controls. Typically, a comment period runs for 30 to 90 days, depending on the government body overseeing the process, before a new rule can go into effect or an existing one can be modified. 

Here’s everything you need to make your voice count while decision makers are listening. 

Educate yourself on the rule in question.

Make sure you read and digest the rule first, so you’ll understand what’s at stake. There are occasions when you’ll come out in support of change, and others when you’ll want to resist change to a rule that’s keeping people safe. 

Come up with your angle.

To make a big impression on the decision makers, think through your stance. Hone in on how this issue is affecting not just you personally but also others in your community. Let’s say you want to weigh in on an opportunity to help cut tailpipe emissions and you live near a highway where the fumes wafting into your neighborhood have caused high asthma rates. Or neighbors are paying way too much for bottled water because they can’t drink safely from their taps. These are all impactful details to emphasize. 

With any rule you want to comment on, it’s important to establish credibility as someone with firsthand knowledge of the given issue; it’s even better if you can represent the concerns of allies so that you’re speaking on the behalf of many. 

The sample below is used with the permission of the speaker.

Hi, my name is Julianna G., and I’m here as a citizen from northern New Jersey and a member of NRDC. I’m here today to advocate for the strictest possible standards for heavy-duty vehicle emissions. On one hand, I believe that incentivizing only the cleanest vehicles and avoiding the use of offsets is critical in combating climate change. But today, I’d like to focus on a more personal reason.

Three people in my household have asthma, and I have a degenerative heart condition. Meanwhile, the historic air quality data from Google’s company BreezoMeter confirms that the long-term particulate matter and ozone levels in my town are far above the safe levels set by the World Health Organization. In fact, according to New Jersey’s Environmental Justice Law, my family lives in one of the state’s “overburdened communities” with regard to pollution.

Emissions from heavy-duty vehicles play a significant role in these dangerous air quality levels, and thus, are largely responsible for the negative consequences to public health. The organization Environment New Jersey reported earlier this year that “medium- and heavy-duty vehicles are responsible for 44 percent of the nitrogen oxide and 39 percent of the particulate matter emitted by on-road vehicles” in New Jersey.

I implore you to protect the health of countless vulnerable citizens like my family members by putting our national bus and truck fleets on a clear and swift path to 100 percent zero-emission, all-electric vehicles by 2035. Thank you for the opportunity to testify.

Craft your comment.

If you’re preparing for an online hearing, plan on speaking for as little time as you’d like but keep to within the established time limits. Often, that’ll be just a few minutes per commenter; after that, you’ll likely be cut off. Remember that one minute covers about 150 words, so plan your comments accordingly. And once you’ve written your thoughts down, practice them so you are familiar with what you want to say. Want to really drive your point home? Consider making a poster or finding a prop to help emphasize your point as you speak.

For a written comment, you’ll want to keep your submission similarly brief—half a page to a page is best, though in some cases you may be able to write up to 1,250 words. 

Build your script.

  • Introduce yourself. Include your job title, where you’re from, or other expertise or affiliations you have that connect you to the topic of the hearing.

  • Name the action you hope to see from the agency. 
  • Give your personal reason for testifying or submitting a comment: Use examples from your own life or community to show why you think action on this topic is important. You might refer to how the issue impacts your state too.
  • Describe the benefits of the action you’re pushing for.
  • Wrap it up and thank the decision makers.

Prepare for participation in a public hearing.

  • You’ll generally need to register in advance to testify at the given hearing. Since the speaking slots sometimes fill up quickly, it’s best to sign up for one as early as possible. (But don’t give up: Most hearings include time at the end for attendees who didn’t get a specific slot to share comments. Some agencies will also maintain wait lists for members of the public who want to speak.) 
  • Once you have registered to speak, you will receive an e-mail with information on how to connect, including a web link and a call-in number for joining by phone. Keep an eye on your inbox shortly before the appointed date.
  • Keep a digital copy of your testimony handy, to share with officials.
  • Plan to show up 20 minutes in advance so you can make sure you have access to the virtual room and to acclimate yourself. It is also possible that there will be additional instructions shared verbally for speakers planning to testify, or that the meeting will be running ahead of schedule. 
  • Be prepared for a wait. Depending on the number of speakers, there may be a delay. (Bottom line: Stay flexible!)
  • You will speak to a panel of officials who are there to listen and take notes. The panel members may ask you clarifying questions about your comments but will not respond to your statements directly.
  • After you have finished providing your testimony, you are free to leave or stay on to hear others comments, if you wish. 

The U.S. Environmental Protection Agency (EPA) is hosting a virtual public hearing on its updated Lead and Copper Rule proposal on January 16, 2023, 11 a.m.–7 p.m. EST. This is the public's opportunity to provide brief comments on the EPA’s proposed rule—and to tell the agency to require water utilities to pay to replace all lead service lines in 10 years. Sign up to speak at the virtual public hearing!

Background

Congress has long recognized the threats of lead in drinking water. In 1974, it passed the Safe Drinking Water Act (SDWA), which required the EPA to set drinking water standards, and it continued in 1986, 2016, and 2019 to amend the SDWA. Each respective amendment reaffirmed the EPA's congressional directive to regulate lead in drinking water by prohibiting new lead pipes from being installed for drinking water and providing grants to replace existing lead service lines.

Now the agency has proposed essential improvements to the Lead and Copper Rule, which will require water utilities to replace all lead service lines, mostly in the next 10 years. These protective regulations would help millions of Americans across the country living in the more than nine million homes currently served by a lead water pipe.

Core Talking Points

  • More than nine million lead pipes are the single-most significant source of lead contamination of water for homes, childcare centers, and other buildings that have them.
  • Lead pipes exist in every single state in our country, and millions are drinking contaminated water from their kitchen taps. 
  • A stronger Lead and Copper Rule is an essential step toward addressing this public health crisis and protecting our children. And improving safe water standards is a core function of the EPA.
  • Lead-contaminated water harms children’s developing brains and behavior, and leads to health issues like kidney and cardiac problems in adults. Lead is harmful to kids’ health, even at very low levels.
  • Children, especially children of color, are facing lifelong impacts from lead contamination. Our communities shouldn’t have to take matters into their own hands to keep their children safe by filtering water or relying on bottled water during crisis after crisis.
  • Health experts agree there is no safe level of exposure to lead. In addition to long-known risks, such as damage to children’s brains and certain cancers, the American Heart Association recently issued a formal Scientific Statement emphasizing there is significant evidence that exposure to lead is linked to numerous cardiovascular diseases, including stroke and heart attack. 
    • The risk of heart disease is especially high in populations of color and low socioeconomic means, due in part to greater lead exposure.
  • While communities across the country of every stripe and income level are affected by lead in water, communities of color and low-income communities are disproportionately harmed.
  • For 30-plus years, the Lead and Copper Rule has failed to protect our drinking water because it only requires action where tests confirm high levels of lead in water. Yet lead testing is so inherently variable, so failures to detect can leave “highly hazardous” taps unremediated.
  • The EPA should follow the examples of states like New Jersey, Michigan, Illinois, and Rhode Island by requiring that every lead service line is removed, and, like New Jersey and Rhode Island, should require that it be done within a decade. 
    • The prioritization of lead service line replacement will lead to tens of thousands of new jobs across the country. In Newark, New Jersey, replacing all lead service lines created significant workforce and job benefits, with the local union providing transferable skills training.

Keep up your activism after your comment submission or testimony.

Here are three ways to stay engaged:

  • Join NRDC’s community to receive e-mails or text alerts about opportunities to comment on environmental policies. 
  • Use your social media accounts to encourage friends and family to testify or comment—the more people the agency hears from, the bigger impact it will make.
  • Pay attention to any forward movement on the issue at hand. If the agency supports your point of view, thank them and recognize their dedication to protecting our environment publicly.

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Speak up at the EPA's public hearing on its proposed Lead and Copper Rule!

The EPA is hosting a virtual public hearing on its Lead and Copper Rule proposal on January 16, 2023, 11 a.m.–7 p.m. EST. This is your chance to pressure the agency to replace all lead pipes in 10 years.

Tell the EPA to Quickly Replace All Toxic Lead Pipes—Quickly!

The U.S. Environmental Protection Agency is hosting a virtual public hearing on its Lead and Copper Rule proposal on January 16, 2023, 11 a.m.–7 p.m. EST. This is your chance to provide comments on the agency's proposed rule—and demand the EPA to require water utilities to replace all lead service lines in 10 years.

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