Intervener Submissions
Environmental Law
Section 3: Organizing, Reviews, and Challenging Issues
Intervener Submissions
Once the notice of hearing has been given, anyone with a genuine interest in the project can file what are called intervener submissions with the NRCB (Natural Resources Conservation Board). People filing these submissions are called interveners (because they are intervening in the process), and their submissions must tell
- what they think the board ought to do about the application
- why they think this
- what information they intend to present as evidence
These written intervener submissions are very important. Usually at the hearing only a brief oral summary of them will be given, but the board will study the written documents in detail. For this reason, it's important to take the time to make a clear, full case in the submission. Submissions often include ideas for alternatives to the proposed project, suggestions to minimize any environmental impact, and restrictions that should be imposed on any licenses given to the applicant. The NRCB (Natural Resources Conservation Board) gives the following suggestions to people writing intervener submissions:
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Clearly state how you think the board should treat the application and why.
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Focus on a few key issues.
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Concentrate on essential information; avoid material that may be interesting but isn't directly relevant.
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Support all factual statements as fully as possible; avoid arguments based on unproven assumptions.
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Be sure to include your arguments and evidence; you should not try to present new material later on at the hearing.
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