It is not just Dow. It happens all the time. A permit is applied for with hypothetical plans based on ..will meet the regulatory requirements.... Then bang once the permit is approved the construction documents are submitted to EPA. The public never gets a chance to evaluate the real project...
This is not true of all companies - some actually do submit construction drawings. There is no requirement to submit the construction plans with the application...
I worked on a hazardous waste landfill for five years. The day after the permit was approved many volumes of construction diagrams were on EPA's desk... EPA called and asked if we would review the newly submitted documents. I said why.. we cannot officially comment or appeal.
In retrospect I wish we had reviewed them and unofficially commented because the landfill is a problem now... But thousands of dollars for consultants and attorneys are spent on information that is deliberately vague... Where values are put in for limits...such as.... the source of coal which is not provided - requiring ranges for different sources of coal.
Bottom line ... public input is a requirement in the regs that many regulators view as a pain and the public is frustrated.
In Toledo right now there is a recalll effort against the Mayor. Local radio and television channels repeatedly comment against the Mayor. No Fairness Doctrine - no other side of the story presented.
Public input, the Fairness Doctrine, newspaper staff reductions and much more put our freedom at risk...and money in control..