• Formulate your arguments to establish a solid groundwork for the entire process, through to appeals and lawsuits.
• Identify key scientific information, analyses, and procedures you want considered; document these in written comments, preferably in the scoping phase, but later is okay too.
• Determine what you want in an ideal alternative and specify how you want this presented.
• Make sure "agreements" are concretely captured in a written alternative.
• No agreement is too obvious to be written down,
• Don't let the agency weasel out of including your alternative unless they can prove to you that it would be illegal.
• Don't let the agency force you to spoon-feed them your alternative in elaborate detail - that's their job. If they have to work through it, they'll retain some degree of "ownership" over that alternative.
• Don't let the agency make your alternative into something other than what you originally intended. This is worse than not including it at all, and will make it tougher to appeal.

©1997 Jim Britell
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May not be reproduced without permission.

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