How to Comment to Federal Agencies

With the advent of direct mail campaigns, high speed internet access and email letter distribution, public lands agencies are adjusting how they read and analyze written comments.

Form letters, letters that are "cut & pasted", post cards and other uniform prepared communications are no longer an effective means for commenting. Computer software programs will cull out identical language. For example, 500 postcards saying the same thing will be counted as one comment. Quality counts; not quantity. Written comments are not votes. Your letters will not be tallied "for" or "against" a proposal.

Many agencies are now centralizing this function in Content Analysis Teams ("CAT"). You may notice in the request for comment notices, that the mailing address for sending comments on many land use management issues is a central location in Utah or Montana. These teams are tasked with the job of synthesizing the pertinent substantive language from every postcard, letter, email and other written material to discern the relevant comments to be used in the formulation of regulatory policies.

Content Analysis Teams systematically identify, organize, summarize and analyze public comment you send in to public lands agencies. Written comments are analyzed and cataloged in a database so that comments can be grouped and sorted according to subject. Issues raised in public comment letters are identified, organized and screened for inclusion in statements which are then forwarded to the public lands agencies.

Content Analysis Team leaders have made some suggestions for writing comments. Below are some tips:

1. Be sure your comments address the proposed regulation or action.
2. Address your comments to the appropriate agency head.
3. Try not to send general statements. Be specific.
4. Identify in your letter how a particular proposed regulation or action can be changed to work better. Identify the specific regulatory section.
5. Don't send rude, obnoxious or demanding letters to an agency. Ask what your response would be if you received this letter.
6. Be constructive with suggestions of how the agency can achieve
its goal(s).
7. Organize your letter to address the specific section of the regulation or proposed action; list your comments in numbered order. Comment on those sections relevant to your concerns.
8. Cite facts and provide background information.
9. Public comment letters addressing proposed changes to agency activities are the place to present your observations and ideas for concrete solutions to problems the agency is attempting to resolve.
10. Email submission is the CAT team's preferred method for receiving comments.
They request that you do not send comments by more than one means. Use email, postal service or fax.

Specifics Count

The more specific your comments, the more impact they will have.  For example if your local land management agency has proposed the closure of trails that you recreate on, point out exactly which trails are important to you and why.  While all comments must be considered it is always better to say that "trail x is important to me because it provides an exceptional recreational experience and it connects to other important trails to form a loop" for example, than simply "please keep all trails open."  While this level of detail may not be possible in all circumstances, where practicable, specific comments will have the most impact.

One way to both hone your comments and to approach an agency action from a broader perspective is to partner with a club.  Local and statewide clubs, along with national organizations, often keep tabs on agency actions and may develop specific comments for the agency action you wish to impact.  Club leaders may also have a better understanding of how areas other than the ones where you recreate are being impacted by an agency action.  If you do not already belong to a club please visit your state's page on the ARRA website to find out who the State Representative for the National Off-Highway Vehicle Conservation Council (NOHVCC) is in your state.  The NOHVCC representative should be able to offer you suggestions about clubs in your area who represent your interests.  If no club in your area represents your interests, NOHVCC may be able to work with you to form one.