This reads like something intended to gain legal approval and avoid litigation rather than promote authentic engagement. For anyone who is not an attorney or agency staff already deeply involved with the program, it is hard to imagine this guidance actually being able to help encourage and gather the views of community members and others who may have important knowledge as well as questions to contribute to the formation of TMDLS and Implementation Plans. Could you not at least place the legal clauses and references at the end of the document? Why not have an explanation in ordinary language that can be understood by community members who might really like to engage, but would be intimidated if referred to this document? Why not have language that articulates the values of engagement that are intended by the document? Are transparency, inclusion, responsiveness, and legitimacy important to the agency, and if so, why not state that?