ABSTRACT

The requirements imposed by environmental permits are similar to statutes and regulations in that they carry the full force of the law and can subject organizations that violate them to enforcement by government agencies and private citizens. They differ, however, from statutes and regulations in how they are developed. Statutes and regulations usually affect many parties, and their development usually involves some degree of lobbying and public participation. In many cases, individual regu­ lated parties need not actively participate in the process, as their interests are adequately protected by trade associations and similar organizations. Although most permitting processes provide for public comment, the applicant will bear the brunt of the effort in obtaining the permit because trade associations rarely involve them­ selves in matters that do not collectively affect their members. If an organization hopes to obtain good permits, it must rely on its own initiative.