The National Environmental Policy Act (NEPA) was enacted in 1970 and requires federal agencies contemplating actions on federally managed lands to assess environmental impacts. This was a groundbreaking piece of legislation that put social and environmental concerns on par with economic considerations in decision making. A critical piece of NEPA is the requirement for public engagement early and often in the process, including public comments. What this means is that every citizen of the United States has the ability to help shape public policy and be a part of the public land decision making process.
Opportunities to help shape land management decisions don’t come along everyday and these decisions can have permanent impacts. This makes it extremely important to get engaged to ensure we have access to healthy, intact habitat for fish and wildlife for generations to come. Land managers need to hear the perspective of hunters and anglers, who have a deep connection with the land and rely on a functioning ecosystem for their pursuits. By taking the time to craft a substantive public comment, you are exercising your democratic right to make your voice heard.
How to write an effective public comment
There is no right or wrong way to provide your input to land management agencies, but there are a few things to keep in mind to make your comment more robust. A well-written and researched comment that is constructive will have the best chance of influencing the proposed regulation.
Crafting Your Comment
Once you have an understanding of the NEPA document and what the agency is planning, you can start to synthesize your thoughts into a comment. You can choose to dive deep into many issues or choose a few issues that are important to you and focus on those. It is not necessarily the length of the comment, but the content you include that makes it substantive. It is wise to be as succinct and clear as possible when writing your comment. An important idea to note is that a comment is not a vote for or against a proposal. The agency is seeking input on how the proposal will impact the environment and the use and enjoyment of public lands. Identify the issue(s) you have, explain your reasoning and do your best to offer constructive solutions ideally with data to support your conclusions.
Questions to ask yourself when creating your comment:
- Is there any information that the agency has failed to include?
- Has the agency used the most relevant and contemporary data?
- Are there any issues that the agency has failed to identify?
- Is my comment constructive?
- Have I discussed my connection and personal experiences within the specific location?
Comments that are emotionally or politically charged or accusatory will garner less attention than constructive comments. Furthermore, comments that do not address the issues, the accuracy of the data or do not relate to the purpose and need described by the agency will hold less weight. Comments should also be clearly written and easy to follow.
Here are some things to avoid:
- Refuting information/data without including reasoning.
- Simply agreeing or disagreeing with the proposal (You can certainly agree or disagree, but you need to include justification).
- Not including references for any new data.
- Being vague, going off-topic, or not relating your comment to issues raised in the document.
Ultimately, a comment is your chance to make your voice heard and can be anything you would like it to be. It is easy to be intimidated, but the agency genuinely wants to hear individual voices to help craft the best policy. These are some suggestions on how to best advocate for what you believe in and produce a comment that will have the best chance of impacting policy. A robust final product depends greatly on the number of stakeholders who provide clear, well-articulated, and well-researched comments. Hunters and anglers have a unique understanding of fish and wildlife and this perspective is vital in the decision-making process.
Note: the comment period for the Rock Springs RMP has been extended until January 17, 2024
Rock Springs RMP Comment Example
October 15, 2023
Bureau of Land Management
Rock Springs Field Office
Kimberlee Foster, Supervisor
280 Highway 191 North
Rock Springs, WY 82901
Re: Rock Springs Draft Resource Management Plan
Dear Ms. Foster,
I appreciate the opportunity to provide comments regarding the Rock Springs Draft Resource Management Plan. I am a member of the Wyoming Wildlife Federation and have pursued mule deer and antelope on BLM land in the Red Desert area for the past five years and have a vested interest in the health of this landscape.
I am in support of managing the Jack Morrow Hills per the Coordinated Activity Plan that was adopted by a vast group of stakeholders in 2006. This plan was well-vetted and balances conservation and other uses based on a ton of input from the 2006 process. This plan is found in the BLM Draft RMP Alternative A (no action).
Additionally, I would like to see updated language to include the mule deer migration corridor and adopt strong management prescriptions that conserve the permeability of the corridor. I recommend the BLM review the latest scientific data collected, cataloged, reviewed, and evaluated by the University of Wyoming's team. In particular, the 2020 peer-reviewed study by Sawyer, et. all discusses a 3% threshold level for migratory disturbance. Not only is it a credible scientific study, but it was also conducted within the deer herd that uses lands administered by the Rock Springs Field Office of the BLM. I would like to see the BLM build management prescriptions on a case-by-case basis in the most important habitats based on this science.
Also, wild horse numbers in the Jack Morrow Hills and Northern Red Desert need continued control as they are extremely territorial and compete for food among ungulates and grazers. Please consider adopting the proposed horse management in the Great Basin Herd Management Area (HMA) in the U.S. Department of the Interior Bureau of Land Management Draft RMP Amendment and EIS for Wild Horse Management and change the Great Basin HMA to a Herd Area (HA). This would be managed for zero wild horses, and if BLM determines there are more than 100 wild horses within the Herd Area, the area will be re-gathered to zero wild horses.
The public lands managed under the Rock Springs Field Office are of significant importance to the hunting and angling community. To hunters and anglers, this is of the utmost importance and will help facilitate a culture of conservation for generations to come.
Frequently Asked Questions
Q1) Why should I write my own unique comment?
Public lands are owned by every citizen of the United States. As such, you have a stake in how those lands are managed. Part of the public comment process is to help the agency understand the environmental, economic, cultural or social implications of a proposed alternative. Public comments can provide the agency with this information. Your voice is a vital part of the democratic process!
Q2) Can’t I just sign a form letter? What is the difference?
You certainly can sign a form letter from an organization you support, but unique comments are more helpful to agency personnel. Remember, this is not a vote for or against a proposed action, the agency is looking to the public to help craft policy and genuinely wants to know how a proposal impacts the public's enjoyment of their public lands. Also, when the agency receives a batch of these form letters, they are only considered as one comment.
If an organization you support has a form letter, it can be a good idea to make that the basis of your comment, and then make additions that are uniquely yours.
Q3) Will the agency read my unique comment?
Yes! In fact, they are required by the Administrative Procedure Act (APA) to read and respond to all relevant unique, fact-based comments. Responses will usually be grouped based on the topic and discussed in the Record of Decision (ROD).
Q4) I spend a lot of time in this area. Should I write about that?
Definitely. On-the-ground observations are critical pieces of data that the agency needs to hear about. For example, if you hunt pronghorn in the affected area and notice that there are fewer animals after a fence or road is constructed, be sure to note that.
Q5) I’ve never been to the area included in the draft RMP, can I still comment?
Yes. As a part owner of federal lands, you have a vested interest and are encouraged to help protect these lands whether you live amongst them or are across the country.
Q6) I have expertise in this area, should I mention that?
Absolutely. Land managers need to hear from people who are experts and this will add to the weight of your comment. Be sure to bring up anything that the agency may have missed or that you think is incorrect.
Q7) There is a lot of technical information and jargon that I don’t understand. Is there someone who can explain it?
Yes! Agency personnel should be able to clarify any questions you may have. Also, be sure to reach out to any NGOs who are involved in the process as they can help as well.
Q8) Writing a unique, substantive comment seems daunting. Can you simplify it?
A comment can be anything you want it to be. You can write an in-depth comment focused on technical scientific data or you can write a few paragraphs explaining your general thoughts. The most effective comments will be constructive and focus on the specific information or lack of information in the document. Identify the issues you have with what the agency is proposing, with reason, and do your best to provide constructive solutions. You do not need to write about everything in the document. Pick a few things that concern or interest you and focus on those. This document will never be perfect, but the idea should be to try to make it as good as it can be and as thorough as possible.
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