Open Public Comments for Land Management Plans
An onX Guide to Writing Substantive Comments
Exercise your democratic right and participate, knowledgeably, in open comment periods that are important to you. We want to equip you with the tools to make an effective impact when writing in. This is your direct line to land managers who dictate recreational access and resource management of our public lands.
What Is a Public Comment
Lands in America hold cherished recreational experiences and resources that fill our freezers, run our cars, and drive our economy. Opinions on how we should use our public lands are as vast as our diversity of ecosystems. It depends on who you ask, and the debate will likely never end between interest groups. But once in a while–potentially every decade or two–any given area is officially under review by the land manager. Debate all you want on social media or with your ol’ Uncle Gunnar at the dinner table, but when these opportunities come along for a place you care about, make yourself heard where it counts.
Comment periods are a window in which a managing land agency or branch of government seeks public input on a proposed plan. The plan could be new, modified, or approaching its termination. Generally speaking, the managing land agency will notify the public that a 30, 60, or 90-day window is open to submit their concerns, opinions, research, or alternatives to the proposed changes. These take place through digital platforms, can sometimes include in-person hearings, and depending on the agency, there may be options to submit comments by mail or over the phone. The agency, after receiving public comments, will consider them in shaping the new rule or plan.
There are countless stakeholders at the table that are impacted by land management plans. A successful scoping process usually results in a compromise, rather than one interest group winning out wholly over the others. Open comments are opportunities for communities to voice their collective needs and wants, and perhaps more importantly, learn the merits and pitfalls of how a shared asset should be managed. It’s fundamental to our system of public lands, but more importantly, the public process is what ensures that our natural resources and natural wonders are best serving current and future generations.
What Makes a Substantive Comment
Odds are, land management officials are receiving lots of public comments, so it’s important to make yours substantive, meaning it’s helpful and it holds weight. To ensure effective use of your time and the managing agency’s, we put together some tips.
The first thing to do is read the plan. While that may seem self-evident, managers can quickly sift through those comments that either don’t reference the plan at all or reference the wrong plan. It’s a surefire way to lose credibility. This is part of a larger effort to educate yourself on the topic. There are several ways to do this—read up about the current management plan that’s in effect, as well as the proposed plan. Attend public meetings, follow advocacy organizations with background on this topic, go visit the place open for discussion if you haven’t already, read news articles about it, and talk with primary stakeholders.
Another way to ensure your comment is substantive is to write a unique letter rather than using a template or form-fill online. Sometimes, agencies will bundle petitions or mass-signature letters altogether and it will have less impact. Those petitions are a great start if you’re short on time, but ideally use the recommended framework below.
Add Your Credentials and Expertise
If you’ve gotten so far as to consider making a public comment, it’s likely because it’s about a subject or location that’s important to you. Introduce yourself in terms of your stake in the area. Make sure the readers know what experience you bring to the conversation and your mastery in the area of discussion. If your family has been recreating in a specific place for generations, mention that. Do you have bona fides in the community like serving as a board member? Those are good too. Provide your contact information if you’re open to follow up conversation about what you’ve provided, but understand that any information you submit during comment periods is entered as record.
Share Impacts on You and the Community
Factors that influence individual and community interest are worthy of a mention. Do you have a business in the area? Share what the proposed changes will do to your customer base. Do you have a neighboring property? Do you run a club, race, or organization? It’s worth mentioning how the new proposed plan may impact you and like-minded people around you.
Use Figures and Data
It’s important to use data, stats, and figures to make your case when writing a public comment. Include economic, scientific, geospatial, and environmental studies that are pertinent. Attach photos, documents, spreadsheets or studies that support your stance.
Additionally, specifics about location are integral components. Trail, road, or zone names are helpful. GPS coordinates are even better. Some agencies allow uploads of maps, images, or documents so you can show, not only tell, them exactly what you are referring to.
Poke Holes and Provide New Info
Identify flaws in the agency’s analysis. Address issues that the plan does not address, and explain why those issues are relevant. Point out what’s unclear. Provide alternative ways to meet a need. If they don’t have all the most relevant or latest data, bring that information to the table. This is where you can drive home your point. Be compelling and solution oriented.
Be Clear and Provide Specific Rationale
We’ll try to be succinct with this one—be direct. The reviewers have lots of comments to consider, make your ask or recommendation explicit.
These comments showcase short, punchy, substantive comments.
- “The agency did not resurvey the area after the wildfire and subsequent blow-down last year, thus the information presented in the plan about the locations frequented by bighorn sheep should be re-examined.”
- “The reasoning for closing Route X is flawed. As evidenced by the attached photos, this road is very well-maintained and accessible. While it is labeled redundant, this track avoids a nearby cultural site in a more practical way than other social trails.” Example provided by The BLM, Utah Division
- “I do not agree with closing Route 317A in Alternative B. This is the only road that provides access to the parcel of state trust land.”
These comments include some combination of specific locations, reasoning, or research that was omitted by the managing agency.
These comments warn against common pitfalls and show what to avoid.
- “I don’t like any of the plans, because none of them stop teenagers from partying on the river, and I’ve never seen anyone out there trying to stop them! This madness has to stop. When I was a kid, all I ever did was fish with my friends, but now kids these days don’t care about fishing, they just care about partying, and the agency lets them do it!”
- “We should not be closing any roads. This is public land. I don’t like any of the closures in Alternatives B, C or D.”
- “The agency doesn’t know where the wildlife even is, I do! I’m out there everyday and I love hunting and I donate a lot of money, and I’m mad!”
These comments provide no new details, rely heavily on opinion, and are too emotional. Unrelated topics or only ‘voting’ for a proposed action or alternative do not hold weight.
Now Is the Time
Whether you’re a first-timer or a long-timer, writing in a public comment is helpful and satisfying. It’s an opportunity to engage in democracy and build an understanding of the lands and communities around you. We encourage you to participate in open public comment opportunities– in your area or places you like to visit. This framework can help you develop a clear, concise, and compelling statement to your land managers.
The most important part of this is that these comment periods are an opportunity for your voice to be heard. It’s a chance to be part of the scoping process when the process is happening. Citizens from all industries and interest groups take part. Don’t be left on the sidelines when our government calls for comment. Our access depends on it. Speak up when the time is right.