Writing a comment letter? Better make it good

Agencies say mass e-mails and form letters don’t mean much

  • Postcards to Congress

 

If you’re a concerned citizen who likes to toss in your two cents about the federal government’s plans for the public lands, a form-letter e-mail — and even a pre-printed postcard and a 23 cent stamp — may not go as far as they used to.

Take the federal Bureau of Land Management’s Rawlins, Wyo., field office, which is updating its 15-year-old blueprint for managing oil and gas drilling, off-road vehicle use, and wildlife on 4.6 million acres. The proposed resource management plan will allow 8,822 new oil and gas wells — more than six times the number allowed under the existing plan. In December, the agency released a draft environmental impact statement and asked for public comment. When the comment period ended on March 18, the BLM had received some 65,000 responses. Most were e-mails and pre-printed postcards put together by the Wyoming Outdoor Council and other local environmental groups, supporting a less-aggressive development alternative.

But the BLM says they may not mean much. "We don’t count votes. We don’t really give any more weight to an issue raised 50,000 times than we do to an issue raised once," says John Spehar, the BLM project leader. "People can’t expect to just send in a postcard without reading the (environmental impact statement) and somehow influence the decision."

It was by no means the first time that the BLM has downplayed the significance of form comments. Last August, the BLM’s Grand Junction, Colo., district office, received 8,888 comments on a proposal to sell oil and gas leases in the South Shale Ridge citizen-proposed wilderness. The vast majority of those were sent to the BLM through a Wilderness Society Web site. BLM District Manager Catherine Robertson allegedly described the response as "a flood of spam." (Robertson declined to comment on the statement.)

The issue isn’t whether comments arrive via e-mail, or on postcards, but whether they are "substantive" — meaning that the agency must address them under the National Environmental Policy Act. While many conservation organizers admit that the definition of "substantive" has always been problematic, the BLM’s new Land Use Planning Handbook, released this March, takes a hard line, asserting that the agency is not required to respond to "opinions, assertions, and unsubstantiated claims."

Bruce Pendery, an attorney for the Wyoming Outdoor Council, says that new tack is worrying: "They will categorize anything they don’t really want to deal with as an opinion. So if you don’t state something in some bald, factual, bland kind of way, you open yourself up to them saying, ‘Well, that’s your opinion, and we don’t respond to opinions.’ "

According to the new planning handbook, "substantive comments are those that reveal new information, missing information, or flawed analysis that would substantially change conclusions." That’s a narrower definition than previously existed — but it also goads citizens to write comments that are more helpful to the BLM.

"It is definitely something we’ve been focusing on: quality comments, rather than volume," says Tova Woyciechowicz, the Wyoming Outdoor Council’s community organizer. WOC and other groups frequently remind their members to elaborate on the cookie-cutter sample letters, and to cite specific sections and page numbers in their responses.

Some BLM field offices have themselves provided specific guidelines for comment writers. Gene Drais, the project manager for the BLM’s Ely, Nev., resource management plan revision, which will be released this summer, says the draft plan will include a "Dear Reader" letter with tips to help readers focus their comments.

But while they acknowledge a need for in-depth comments, environmental organizers say that sheer numbers are still an important barometer of public concern. The Clinton-era roadless area conservation rule, for example, garnered some 1.6 million public comments, the vast majority of which were in favor of roadless-area protection. Although more than a million responses were form letters, the Clinton administration and the Forest Service widely advertised that response as justification for adopting the rule.

Conservation groups are trying to play a similar card in their efforts to keep oil and gas drilling off the Roan Plateau, another citizen-proposed wilderness in western Colorado: They rallied many of the almost 75,000 comments the BLM received on that plan. And environmental groups are gearing up to organize public comment on 23 draft resource management plans that the BLM will release in eight states around the West in the next 12 months.

The bottom line, say organizers, is that sending in something is always better than sending in nothing. "We always want to see as many comments as possible," says Mark Schofield, a community organizer for Western Colorado Congress. "It’s key that decision makers know the numbers of people out there (with the) commitment to take some kind of action to make their voice heard."

The author is HCN associate editor.

High Country News Classifieds
  • ARKANSAS RIVER COMMUNITY PRESERVE LAND MANAGEMENT PLANNER
    Central Colorado Conservancy seeks a land management planner to facilitate the creation of a management plan for the Arkansas River Community (ARC) Preserve on a...
  • WATER ADVOCACY MANAGER
    Do you want to help shape the future of groundwater in the Grand Canyon region? The Grand Canyon Trust is hiring its first water advocacy...
  • EXECUTIVE DIRECTOR
    California Coalition for Rural Housing (CCRH) seeks a strategic and visionary Executive Director: View all job details here- https://bit.ly/CCRHED
  • MONTANA BLUES
    The new novel by Ray Ring, retired HCN senior editor, tackles racism in the wild, a story told by a rural White horsewoman and a...
  • DIGITAL ENGAGEMENT SPECIALIST
    Title: Digital Engagement Specialist Location: Salt Lake City Reports to: Communications Director Status, Salary & Benefits: Full-time, Non-Exempt. Salary & Benefits information below. Submission Deadline:...
  • CONSERVATION FIELD ORGANIZER
    Title: Conservation Field Organizer Reports to: Advocacy and Stewardship Director Location: Southwest Colorado Compensation: $45,000 - $50,000 DOE FLSA: Non-Exempt, salaried, termed 24-month Wyss Fellow...
  • UTAH STATE DIRECTOR
    Who We Are: The Nature Conservancy's mission is to protect the lands and waters upon which all life depends. As a science-based organization, we create...
  • EXECUTIVE DIRECTOR
    Apply by Oct 18. Seeking collaborative, hands-on ED to advance our work building community through fresh produce.
  • INDIGENOUS AFFAIRS EDITOR - HIGH COUNTRY NEWS
    High Country News is hiring an Indigenous Affairs Editor to help guide the magazine's journalism and produce stories that are important to Indigenous communities and...
  • STAFF ATTORNEY
    Staff Attorney The role of the Staff Attorney is to bring litigation on behalf of Western Watersheds Project, and at times our allies, in the...
  • ASSISTANT VICE PRESIDENT FOR DIVERSITY AND INCLUSION
    Northern Michigan University seeks an outstanding leader to serve as its next Assistant Vice President for Diversity and Inclusion. With new NMU President Dr. Brock...
  • EXECUTIVE DIRECTOR
    The Clark Fork Coalition seeks an exceptional leader to serve as its Executive Director. This position provides strategic vision and operational management while leading a...
  • GOOD NEIGHBOR AGREEMENT MANAGER
    Help uphold a groundbreaking legal agreement between a powerful mining corporation and the local communities impacted by the platinum and palladium mine in their backyard....
  • EXECUTIVE DIRECTOR
    The Feather River Land Trust (FRLT) is seeking a strategic and dynamic leader to advance our mission to "conserve the lands and waters of the...
  • COLORADO DIRECTOR
    COLORADO DIRECTOR Western Watersheds Project seeks a Colorado Director to continue and expand WWP's campaign to protect and restore public lands and wildlife in Colorado,...
  • ASSISTANT PROFESSOR OF HISTORY - INDIGENOUS HISTORIES OF THE NORTH AMERICAN WEST
    Whitman College seeks applicants for a tenure-track position in Indigenous Histories of the North American West, beginning August 2024, at the rank of Assistant Professor....
  • DAVE AND ME
    Dave and Me, by international racontuer and children's books author Rusty Austin, is a funny, profane and intense collection of short stories, essays, and poems...
  • CHIEF FINANCIAL OFFICER
    Rural Community Assistance Corporation is looking to hire a CFO. For more more information visit: https://www.rcac.org/careers/
  • EXECUTIVE DIRECTOR
    The Absaroka Beartooth Wilderness Foundation (ABWF) seeks a new Executive Director. Founded in 2008, the ABWF is a respected nonprofit whose mission is to support...
  • CANYONLANDS FIELD INSTITUTE
    Field seminars for adults in natural and human history of the northern Colorado Plateau, with lodge and base camp options. Small groups, guest experts.