How to Write Effective Comments

Tips for Submitting Effective Comments in Land Manager Actions
Overview
A comment can express simple support or dissent for a regulatory action. However, a constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making.
These tips are meant to help the public submit comments that have an impact and help agency policy makers improve federal regulations.
Summary
  • Read and understand the regulatory document you are commenting on
  • Feel free to reach out to the agency with questions
  • Be concise but support your claims
  • Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
  • Address trade-offs and opposing views in your comment
  • There is no minimum or maximum length for an effective comment
  • The comment process is not a vote – one well supported comment is often more influential than a thousand form letters
  • You may submit many separate comments, they do not have to be posted all at once. As you think of something, post it.
Detailed Recommendations
Comment periods close at 11:59 eastern time on the date comments are due – begin work well before the deadline.
Attempt to fully understand each issue; if you have questions or do not understand a part of the regulatory document, you may ask for help from the agency contact listed in the document.
Note: Although the agency contact can answer your questions about the document’s meaning, official comments must be submitted through the comment form.
Clearly identify the issues within the regulatory action on which you are commenting. If you are commenting on a particular word, phrase or sentence, provide the page number, column, and paragraph citation from the federal register document.
If a rule raises many issues, do not feel obligated to comment on every one – select those issues that concern and affect you the most and/or you understand the best.
Agencies often ask specific questions or raise issues in rulemaking proposals on subjects where they are actively looking for more information. While the agency will still accept comments on any part of the proposed regulation, please keep these questions and issues in mind while formulating your comment.
Although agencies receive and appreciate all comments, constructive comments (either positive or negative) are the most likely to have an influence.
If you disagree with a proposed action, suggest an alternative (including not regulating at all) and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective.
The comment process is not a vote. The government is attempting to formulate the best policy, so when crafting a comment it is important that you adequately explain the reasoning behind your position.
Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, fisherman, businessman, etc.) say so.
Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well you are more likely to influence the agency decision making.
Consider including examples of how the proposed rule would impact you negatively or positively.
Comments on the economic effects of rules that include quantitative and qualitative data are especially helpful.
Include the pros and cons and trade-offs of your position and explain them. Your position could consider other points of view, and respond to them with facts and sound reasoning.
If you are uploading more than one attachment to the comment web form, it is recommend that you use the following file titles:
Attachment1_<insert title of document>
Attachment2_<insert title of document>
Attachment3_<insert title of document>
This standardized file naming convention will help agency reviewers distinguish your submitted attachments and aid in the comment review process.
Keep a copy of your comment in a separate file – this practice helps ensure that you will not lose your comment if you have a problem submitting it using the Regulations.gov web form.
Specific Requests
The BLM has specifically requested public comment on the following aspects of the conservation lease proposal in the Conservation and Landscape Health Rule.
• Is the term “conservation lease” the best term for this tool?
• What is the appropriate default duration for conservation leases?
• Should the rule constrain which lands are available for conservation leasing? For example, should conservation leases be issued only in areas identified as eligible for conservation leasing in an RMP or areas the BLM has identified (either in an RMP or otherwise) as priority areas for ecosystem restoration or wildlife habitat?
• Should the rule clarify what actions conservation leases may allow?
• Should the rule expressly authorize the use of conservation leases to generate carbon offset credits?
• Should conservation leases be limited to protecting or restoring specific resources, such as wildlife habitat, public water supply watersheds, or cultural resources?
Posted Comments
After submission, your comment will be processed by the agency and posted to Regulations.gov. At times, an agency may choose not to post a submitted comment. Reasons for not posting the comment can include:
  • The comment is part of a mass submission campaign or is a duplicate.
  • The comment is incomplete.
  • The comment is not related to the regulation.
  • The comment has been identified as spam.
  • The comment contains Personally Identifiable Information (PII) data.
  • The comment contains profanity or other inappropriate language.
  • The submitter requested the comment not be posted.
Form Letters
Organizations often encourage their members to submit form letters designed to address issues common to their membership. Organizations including industry associations, labor unions, and conservation groups sometimes use form letters to voice their opposition or support of a proposed rulemaking. Many in the public mistakenly believe that their submitted form letter constitutes a “vote” regarding the issues concerning them. Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound reasoning and scientific evidence rather than a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.



Learn Why the Proposed BLM Rule Will Devastate Access




Why and What You Can Do to Stop the BLM Rule

Is the sky really falling this time?

If the proposed BLM Conservation and Landscape Health Rule is adopted, the sky will fall for Utah BLM land visitors that enjoy the use of any kind of motorized or wheeled vehicle. This will devastate your use of not only Off Highway Vehicles, but also access to trail heads for equestrians, base jumpers, and rock climbing routes. This is a Federal Rule, so BLM lands across our nation will be affected.

Comments are due by July 5, and now is the time to speak out against this rule.

SEND YOUR COMMENTS TO BLM BY CLICKING ON THIS LINK

The stated purpose by the BLM Director for the Rule is to “Protect the Best and Restore the Rest” They will achieve this by doing all of the following:

  1. The extreme environmental groups behind this Rule have long sought to designate more land as Wilderness. This most restrictive designation will mean that not only OHV users, but mountain bikers, rock climbers, base jumpers, rock hounders, snowmobilers, and even equestrians will be denied access to our lands. If you’re handicapped, leave your wheelchair at home because any type of “wheeled vehicles” are also prohibited. The Red Rock Wilderness Act in the Senate will also designate 8 million acres land as wilderness in Utah, that’s 35% of BLM land in Utah.
  2. Expansion of ACECs- There are already 70 Areas of Critical Environmental Concern (ACEC) in Utah. The rule will direct BLM to aggressively identify even more areas to be designated ACEC and will allow the Director to make these designations largely without any public input. It will then require BLM to aggressively adopt rules against all the negative impacts caused by grazing, mining, Off Highway Vehicle Use and many others. There are already many horrible impacts being caused by this, in Oregon private homeowners have cut off access to their homes because the road crossed ACEC boundaries.
  3. Restoration-It will require BLM to focus on conservation efforts to return areas back to natural conditions, wiping out roads and dispersed camping-the first step in a wilderness designation.
  4. Land Conservation Leases- Rules allows BLM to grant Land Conservation Leases to “qualified individuals, companies, or organizations” to manage the land to achieve the desired conservation measures.
    1. There is no definition of what “qualifications” are required, but in addition to the potential impact of allowing extremist conservation groups to further restrict access, there is also a strong threat to national security because it could allow control by foreign interests. For example, if our grazing or farming lands are controlled by foreign interests, our food supply and national security will be impacted.
    2. Memorandums of Understanding (MOU) are likely to be used to state the objectives and responsibilities associated with the leases, but the Federal Government has far more failures associated with enforcing MOUs than successes. That means once they are granted, the rules can be thrown out the window.
    3. Companies that have negative impacts on the environment will be permitted to offset their negative impacts by entering into Conservation Leases on what previously were “public lands” They will be encouraged to aggressively restrict as much use as possible to achieve the maximum offset for their harmful activity elsewhere.
    4. The BLM specifically requests public comment on the following aspects of the conservation lease proposal in the Conservation and Landscape Health Rule.
      • Is the term “conservation lease” the best term for this tool?
      • What is the appropriate default duration for conservation leases?
      • Should the rule constrain which lands are available for conservation leasing? For example, should conservation leases be issued only in areas identified as eligible for conservation leasing in an RMP or areas the BLM has identified (either in an RMP or otherwise) as priority areas for ecosystem restoration or wildlife habitat?
      • Should the rule clarify what actions conservation leases may allow?
      • Should the rule expressly authorize the use of conservation leases to generate carbon offset credits?
      • Should conservation leases be limited to protecting or restoring specific resources, such as wildlife habitat, public water supply watersheds, or cultural resources?

The Rule is unnecessary and illegal. SUWA has claimed that conservation has not been adequately addressed by BLM in their land use decisions, yet this is just untrue. Every land use decision has to run through a gamut of checklists, and 90% of those items concern conservation or protection items. There are already dozens of Acts of Congress that must be complied with including requirements of the Wilderness Act, Clean Water Act, Clean Air Act, Antiquities Act, Endangered Species Act, Archeological Protection Act, and NEPA.

UPLA has commented, but UPLA can’t vote. We need you to take action to submit comments online before July 5. Be sure to tell them to remove the Rule, but also  give them your reasons for doing so.

Don’t be confused about Congress taking action to protect us. 2 bills have been introduced in Congress that would overturn the power of BLM to adopt a rule like this, but they have only been introduced, not passed. Get your comments done today or quit complaining when your favorite trails and routes are closed.

One final request, share this message with everyone you know on social media, email, or conversation. Make sure if you’re part of a club or organization that everyone knows about this Rule and the impact it will have.

Sincerely,

 

Loren Campbell
UPLA President

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Urgent-Take Action to Stop Adoption of BLM Rule

The Bureau of Land Management Conservation and Landscape Health Rule (BLM-2023-0001) is threatening to strip away access to public lands that belong to all of us. This rule would allow wealthy organizations to take control of our precious lands, eliminating our access to BLM lands. We cannot sit idly by and watch as our land is sold to the highest bidder. It’s time to take action and stop this rule change before it’s too late. Join us in the fight to preserve our public lands for future generations by going to Regulations.gov and submitting your reasons this rule should be rejected. When submitting comments, the field is limited to 5000 words, so if you have more than that, you may want to attach a document instead.

You can find UPLA’s comments documenting our strong opposition here.

Congress is working to reject adoption of this proposal with H.R. 3397 and we are working on gaining Congressional support, but we cannot count on that solution.

As of today’s date, there have been 82,610 comments already posted on the BLM website, and a quick scan of recent comments shows that more comments are in favor of the Rule have been filed. We must rise to the challenge and get our side of the story on record. Together, we can make a difference and ensure that our natural resources remain in the hands of the people who cherish them most, but it requires your action now.

BLM restrictions on access are already very limiting, but adoption of this Rule will place extreme conservation groups like SUWA to determine who and how BLM land is used..

Stop This Change by going to Regulations.gov and make your comments today. 

Please share this message with all your friends, and email us with your BLM comment tracking number.




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