Make Your Comment Count
Tips for comments to land management agencies:
If you follow these straightforward steps, you’ll successfully craft a “substantive comment” – a comment that the Bureau of Land Management (BLM) must consider during their planning processes.
How does the BLM define a substantive comment?
BLM defines a substantive comment as one that:
- questions the accuracy of information, methodology or assumptions used in the analysis,
- presents new information or reasonable alternatives not analyzed, or
- causes changes or revisions.
“To be most helpful,” the BLM notes, “comments should be as specific as possible.”
A substantive comment does one or more of the following:
- provides new information about the Proposed Action, an alternative or the analysis
- identifies a different way to meet the need
- points out a specific flaw in the analysis
- suggests alternate methodologies and the reason(s) why they should be used
- makes factual corrections
- identifies a different source of credible research which, if used in the analysis, could result in different effects
What are some good examples of a substantive comment?
Please note these are generic examples and are not specific to any particular planning process.
“Several alternatives are purported to reduce fire risk through the construction of firebreaks. Where is the science indicating that constructing fuel breaks reduces fire risk or extent?”
“None of the alternatives restrict motor vehicles, ATVs and dirt bikes to designated routes. That failure will lead to continued degradation of sage-grouse habitat, as ATVs and dirt bikes roam, creating still more routes that subdivide blocks of habitat. “Existing routes” in many cases are excessive routes, including unplanned and redundant ORV tracks. Some should be closed to prevent further degradation of habitat.”
“Livestock grazing also leads to cheatgrass invasion, as overgrazing eliminates native bunchgrasses and degrades biological soil crusts, both of which represent the ecosystem’s natural defenses against this invasive weed (Reisner et al. 2013, Attachment 18). In order to minimize the spread of cheatgrass, livestock forage removal limits need to be set under the RMP amendment, allowing no more than 25% of the available forage to be consumed each year (see Braun 2006, Holechek 2010). BLM must restore degraded habitats by managing for the elimination of cheatgrass from the system.”
What are some examples of non-substantive comments?
“I do not support Alternative D.”
“Protect our resources!”
“Please extend your office hours for those who work between 8 a.m.-5 p.m. Monday-Friday.”
In The News: Proposed New “Public Lands Rule”
The Bureau of Land Management’s proposed new “Public Lands Rule” could be a win for Oregon’s high desert. On March 30, 2023, the Bureau of Land Management announced an anticipated […]Read More
A Brief History of Public Lands
Native lands first America’s public lands, including those in present-day eastern Oregon, are filled with signs of the Indigenous people who inhabited those areas since time immemorial. Rock art, artifacts […]Read More