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GUIDE 1: HOW TO PREPARE EFFECTIVE PUBLIC CONSULTATION WRITTEN COMMENTS

Rather than making generalized statements about how the project will affect you, your community, or the surrounding environment, your comments will be more effective if they specify provisions of domestic laws and regulations that the EIA or proposed project violate.

 

As our Portuguese constitution guarantees access to clean water and guarantees a right to live in a healthy environment, it is recommended that these legal rights be highlighted in your written comments if they are likely to be affected by any proposed oil & gas exploration project (onshore and offshore).

 

 

Submitting written comments is important for demonstrating, in later stages, that you participated in the EIA review.

If you decide to appeal the approval of an EIA for a particular exploration project, your case will be stronger if your written comments cover all the issues you may later want to raise in court.

 

 

List of Environmental Attributes that you need to consider when writing your comment

This list, gives you some idea of impact areas when you are writting your submission. Responses to the Identification of Environmental Impacts can be framed by answering the question:

Does the undertaking or related activities (during construction, operation or maintenance) have the potential to affect or be affected by any of the following environmental attributes? If so, then describe the impact and the proposed mitigation.

Note: the following is a guide only and is not intended to be an exhaustive or a prescriptive list.

 

Air Quality

• Particulate/smoke
• Dust
• Odours/Fumes
• Visibility
• Primary chemical loadings (NOx, SOx etc.)
• Secondary chemical loadings (e.g., Photochemical smog)
• Greenhouse gases

Biology and Ecology (Aquatic)

• Deep-sea marine habitat (seasonal and permanent)
• Inshore marine habitat (seasonal and permanent)
• Inter-tidal marine habitat (seasonal and permanent)
• Lacustrine habitat (seasonal and permanent)
• Fluvial habitat (seasonal and permanent)
• Wetland habitat (seasonal and permanent)
• Spawning, feeding, and breeding sites
• Populations/communities of aquatic species (including flora, fish, birds, marine mammals, etc.)
• Species diversity and variety
• Species at risk and other species of conservation concern
• Migration routes/movement corridors
• Aquaculture
• Sports fisheries
• Commercial fisheries
• Subsistence fisheries
• Native (cultural) fisheries

Biology and Ecology (Terrestrial)

• Natural vegetative cover/Vegetation communities
• Virgin/old growth timber stands
• Farmland/crops/domestic livestock/orchards
• Agricultural capability
• Migration routes/movement corridors
• Temporary (seasonal) habitat
• Permanent habitat
• Nesting, breeding, and feeding sites
• Size and distribution of populations/communities (animals, birds reptiles, amphibians, insects)
• Species at risk and other species of conservation concern
• Species diversity and variety
• Sport, recreational, commercial, subsistence hunting/trapping/gathering
Physical (Climate/Atmosphere)
• Macro-climate
• Micro-climate
• Temperature
• Humidity
• Wind patterns/air circulation
• Precipitation patterns
• Fog
• Thermal inversions
• High level ozone (ozone layer)
• Shadow effects/sun blockages
• Noise or vibration

Physical (Geology)

• Aggregate or mineral resource potential
• Rock pressure
• Geochemistry (e.g., acid rock drainage etc.)

Physical (Geomorphology)

• Landforms, topography
• Soil erosion
• Soil permeability
• Total site imperviousness
• Ground transmitted noise/vibration
• Soil bearing capacity/settling/liquefaction
• Slope stability/earth slides/rock slides/slumps
• Aggregate or mineral resource potential
• Soil fertility
• Soil moisture/drainage

Physical (Groundwater)

• Quantity (aquifer yields etc.)
• Quality (e.g., salinity, nitrates, toxic substances)
• Base flow to streams/springs/seepages
• Depth to water table (mounding, drawdown, etc.)
• Flow direction
• Recharge areas
• Domestic/municipal/industrial/agricultural supplies

Physical (Surface Water)

• Quantity of flowing and standing water (rivers, lakes, and streams)
• Quality of water (temperature, BOD, dissolved oxygen, bacteria, turbidity (suspended solids, sediments), nutrients, pH, pesticides, chlorinated organics, trace metals, hydrocarbons, misc. toxics, salinity, taste, odour, floating debris)
• Tidal patterns and ranges
• Quantity and quality of wetlands
• Flood frequency/magnitude/elevation
• Currents/ circulation patterns
• Wave patterns
• Beaches/dunes (size and substrate)
• Flow regime (variability, frequency, velocity)
• Domestic/municipal/industrial/agricultural supplies
• Thermal regime (stratification)
• Chemical equilibrium/mobilization (movement between sediments and water column)
• Trophic state
• Drainage patterns, catchment boundaries hydrologic transfers/losses
• Unique physical features
• Shoreline processes (erosion, transportation, deposition)
• Channel morphology, configuration

Valued Spaces/Locations

• Significant structures, sites, monuments, objects
• Archaeological sites
• Paleontological (fossil) sites
• Areas of special local significance (spiritual, cultural, ecological)
• Parks and reserves
• Sites of educational, scientific, natural, or historical interest
• Visual character (scenery, views, vistas)
• Ornamental features (plantings, landscaping)
• Unique physical features

Community Structure (Socio-economic)

• Population size and density
• Housing availability
• Public health
• Incomes levels
• Employment opportunities
• Municipal income (tax base/grants, etc.)
• Property values
• Municipal expenditures

Community Structure (Physical and Functional)

• Land use compatibility
• Temporary or permanent barriers to vehicular/pedestrian movement
• Temporary land use restrictions/disruptions
• Municipal infrastructure, utilities, fire/police protection
• Transportation patterns (modes and routes)
• Traffic volumes
• Access to and within farms, homes, businesses, industries
• Operational practices of farms, businesses, industries

Lifestyle and Quality of Life

• Access to existing recreational opportunities
• Cultural facilities
• Congestion
• Community noise levels/vibration

 

 

Disclaimer: The guidelines in this article is intended to serve as a guide and is not intended to be legal advice. Please seek professional help from a lawyer if you have legal questions or concerns.

 

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