Drafting

All of the reports that we produce are submitted to the lead agency (the state or federal agency responsible for licensing, permitting, or funding a given project) for comments. The purpose of this practice is to provide the agency a chance to give feedback on the environmental review process before we finalize the work. Ideally, the report is done well enough that the agency provides few, if any, comments. Realistically, if all else fails, the agency folks will provide comments (sometimes accurate, sometimes not) about the grammar. Really, some of these folks are that bored.

More substantive comments are also common. When, as is not uncommon, one or two people produce a 400-page report (complete with all of it's appendices) in the space of two weeks, it is inevitable that something will be unclear or missing from the report, and agency comments will point this out.

On other occasions, an agency will allow someone who has no knowledge of the relevant subjects to review a document. In those cases, the comments are often nonsensical. For example, one report that my company submitted to a state agency was returned with a comment stating that the report had failed to explain how the proposed project would impact a known Native Californian village site. We responded by contacting the agency and explaining that the village site in question was six miles from the project location and was separated from the project location by a mountain range, and therefore there were no impacts. The agency responded by demanding that we explain how the proposed project would impact the village. We responded again by explaining the distance and the mountain range, the agency demanded that we explain the impacts (apparently failing to grasp that six miles and a mountain range is sufficient buffer to keep a graded dirt road from impacting a site), and so on for several months.

One state agency, which shall remain un-named, has even elevated abusive comments into an art form. I once received a comment from this agency informing me that a report I had written "has a whining, petulant tone that the reviewers found offensive." If you have ever read one of these documents then you'll know that the notion that they can have a tone other than "dry and boring" is comical. This same agency, one seeing the field schedule for an excavation project, wrote that "a quadriplegic without his wheelchair could dig faster than this!"

As amusing as those comments are, at least that particular agency has a reputation for knowing their own regulations and applying them evenly, correctly, and fairly across the board. In order to provide a contrast, I have to explain that when a report is submitted to an agency, it is called a "Draft" report, and will become a "Final" report once comments have been received and incorporated into the document.

Now for the contrasting agency. We work, routinely with a federal agency (that shall also go un-named) that has offices throughout California, and most of the people in most of these offices are good at their jobs and pleasant to work with. But every now and again we hit up against someone who isn't. In this case, we submitted a draft report for agency comments. The agency archaeologist took exception to this, apparently viewing it as an insult that we would submit a draft report and not a final report. So, they shredded the document and demanded a final report.

Of course, going by this agency's own processes, we can't actually generate a final report until after the agency has commented on the draft report. The report was, therefore, re-submitted with an explanation that we were waiting on comments so that we could issue a final report. The agency shredded that one and demanded a final report.

And so, we find ourselves in a position where we are being held responsible for actually following the agency's own requirements.

Fnord!