Public Comments: How to Make Yours Count

Your public comment can make a difference, especially if it’s in your own words

By Benjamin Alva Polley

January 17, 2024

Photo by Tzido/iStock

Photo by Tzido/iStock

We’ve all been there. We thought we were doing our civic duty, participating in democracy by auto-filling our names and addresses on form letters sent out by our trusted NGOs, adding our voices in the public comment period on public lands, wildlife, or social justice issues. But does it do any good? Being engaged does matter, but we can do better. For that you need to know how public comments work.

Ensuring that members and supporters get their voices heard is an integral part of the Sierra Club’s grassroots campaign work, says director of land protection Athan Manuel. Agencies want to see what the public thinks about specific issues, and flooding them with form letters can matter. “It is important when there’s a comment period that we get more comments than the opposing side,” says Manuel. But it might depend on what political party is in office at the time. “When Democrats are in charge, they take these numbers very seriously. They want to say, 'Look, when we came to the final decision on X, one of the reasons we did that is the science. The other reason is that 90 percent of the comments from the American public asked us to do X.'” Republicans, he says, don’t value public opinion the same way. “They come in with an ideology and do whatever the oil, mining, and timber industries want them to do.”

For the agencies’ purposes, however, the sheer number of comments doesn’t necessarily matter. According to the Bureau of Land Management’s website, BLM may receive hundreds or even thousands of form letters stating the same thing from different individuals but count them as a single comment.

“The NEPA public comment process requires the proponent agency to respond to the issues raised by public comments,” says Jeff Ruch, Pacific director at Public Employees for Environmental Responsibility (PEER). “One letter raising five issues will require the agency to respond to each of those issues. By contrast, if you have 100 comments raising the same issue, the agency needs to respond to that one issue only.”

For example, BLM received 17,200 comments from form letters against opening the National Petroleum Reserve in Alaska for drilling by ConocoPhillips Willow Project. But the agency counted all 17,200 as a single comment because they essentially say the same thing.

The BLM recommends that public comments on proposed rules be specific, confined to issues pertinent to the agency’s proposal, and explain any changes the writer would endorse. They also recommend referencing the particular section or paragraph that your comment addresses. Physical letters may have the most weight, because of the time they take. Other comments with impact are those that are original and supported by quantitative information or studies, and that include citations and analysis of applicable laws or regulations. People can use these guidelines to edit form letters before sending, picking out what resonates most and rewriting them in their own words in a few sentences. It might take a few minutes longer, but the difference can be large.

NGOs should also be aware that when and how the form letters are delivered can make a difference. “If you deliver them as one big file, then they are going to count as one, but if people send individual emails, then they count those separately,” says Manuel.

Organizations like the Sierra Club, Wild Earth Guardians, and Defenders of Wildlife work hard to ensure that their digital campaigns land correctly. They struggle with how to keep their campaigns from losing steam, how to keep the public engaged, how to maximize public participation, and what will most likely sway agencies' decisions. “A lot of times, agencies want numbers,” says Manuel. “The key thing is to mix it up, be open-minded and creative where possible.”

3 Steps to Make Your Public Comment Count

  1. Be specific. What are you responding to? What do you want?
  2. Use data. Can you back up your argument? Include the source of your information.
  3. Be original. Use your own words to explain why the issue matters to you.