Student Resources

This page includes many resources that will help you, as a student volunteer, complete your NEDC projects. It will likely provide a good starting point for your research, and may address some of the issues you encounter along the way. Thanks for your participation, and please feel free to contact the NEDC office with any questions.

Commenting Resources

Why Do We Comment?

Congratulations! You volunteered to work on a comment for NEDC. But maybe you aren’t sure where to start or why commenting is important. 

Watch this presentation

NEDC’s Guide to Permit Commenting

Prepared by the staff of NEDC, this guide gives a quick overview of administrative law and explains how citizens can influence agency decisions, including the issuance of permits under the Clean Water Act and Clean Air Act.

Download the guide here.

Permitting an End to Pollution

This is a very thorough yet highly accessible guide to reading and commenting on Clean Water Act NPDES permits. Prepared jointly by the Prairie River Network, the Clean Water Network and the River Network.

To view or download the Guide, click here, then scroll to the bottom of the page.

The Proof is in the Permit

Subtitled “How to Make Sure a Facility in Your Community Gets an Effective Title V Air Pollution Permit”, this guide provides excellent advice for reviewing and commenting on Clean Air Act Title V permits.

View or download the guide here.

NEDC’s Coastal Water Pollution Permit Commenting Guides

NEDC has developed two straightforward, easy-to-use guides to commenting on Oregon coastal water pollution permits. Our Sewage Treament Plant Citizen’s Guide focuses on issues specific to coastal sewage treatment plant water pollution discharge permits, while our Construction Stormwater Run-Off Citizen’s Guide addresses pollution related to coastal development.

Additional Resources

These books can be found at the Lewis & Clark Law School’s Boley Library

The Art of Commenting, by Elizabeth Mullin, has great advice on how to influence agency decisions by commenting and public participation.


Model Comments

No need to reinvent the wheel! Below are links to comments submitted by NEDC that may be helpful in drafting your own - feel free to use them as a model. They are organized first by category, then by type of permit or agency action.


1200-C Stormwater Permit (General NPDES Permit)

Kosta Scrap Metals (General 1200-COLS NPDES Permit - Water Quality & TMDLs)

Weyerhauser North Bend (Individual NPDES Permit - Industrial Process Wastewater)

City of Salem (Individual NPDES Permit - Municipal Sewage Treatment Plant)

Premier Dairy (Individual NPDES Permit - CAFO)

Burlington Northern (Section 404 Dredge and Fill Permit)

GP Toledo (Petition for Reconsideration of an NPDES Permit)


SP Newsprint (Title V Permit Renewal)

PGE Boardman / CAMR (DEQ Implementation of the Clean Air Mercury Rule)

Wah Chang Albany (Facility Performing a Major Modification and Avoiding New Source Review)


Bull Trout Critical Habitat (Critical Habitat Designation)

Toolbox Timber Sale (Salvage Timber Sale Draft EIS)

BLM Western States EIS (Regional EIS)

Orca Whale Comments (ESA Listing)

Ochoco NF Scoping (Public Lands Grazing Allotment)

Orchard Project EA (Environmental Assessment)


Westwind Pictures

Photos courtesy of Andrew Burdick Photography