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 1 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 is 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.

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