Crafting a substantive comment is the best way to make sure your voice is heard

Under federal law, agencies must respond to all “substantive” written comments submitted during the public comment period in the final plan. But – even if your comment doesn’t qualify as substantive it can still make a difference. BLM and USFS have stated that any comments showing support of Alternative E will be taken into consideration in the decision making process, but public comment does not function as a popular vote.

Want to submit a substantive comment? This is what qualifies as Substantive:

Substantive Comments

Substantive Comments consist of one or more of the following criteria:

  • questions the accuracy of information
  • questions the adequacy of, methodology for, or assumptions used for the environmental analysis
  • presents new information to the analysis (including Traditional Indigenous Knowledge in the form of stories passed down from ancestors and elders)
  • presents reasonable alternatives other than those that are already in it

Substantive comments may result in the following:

  • in modifying one or more of the alternatives as requested
  • developing and evaluating suggested alternatives
  • supplementing, improving, or modifying the analysis
  • making factual corrections
  • causing changes to one or more of the alternatives
  • supporting the preferred Alternative as the best plan for the Monument

Non-Substantive Comments

Agencies are not required to respond to non-substantive comments or comments that are received late.

A “non-substantive comment” consists of one or more of the following:

  • general comments in favor of or against the draft plan (for example – “I like this plan” with no explanation as to why)
  • comments that only agree or disagree with BLM policy or resource decisions without justification or supporting data (for example – “I don’t like this plan,” with no explanation as to why)
  • comments that don’t pertain to Bears Ears or the project (for example – “this plan reminds me of the plan for Chaco Canyon, which I didn’t like.”)
  • comments that are vague or open-ended questions (for example – “why did the agencies choose this alternative? Help me understand.”)

Additional tips for writing a substantive comment:

Agencies prefer that people submit comments in their own words, instead of using generic form letters. Although we have offered a template and key points to guide you in writing your comment, we encourage you to rewrite the form letter in your own words. We encourage you to address specific aspects of the Bears Ears plan that speak to  you, and tailor your comments to incorporate your unique personal connections, experiences, and observations.

When possible, incorporate information into your comments. Remember that Traditional Indigenous Knowledge is data! If you have heard stories from elders about Bears Ears, that is data and you can include that as information that justifies your public comment. If you are relying on western data, provide references or web links to studies to ensure that the agencies have access to the referenced information.

Describe your connection to the Bears Ears living landscape. Even if you don’t live near the Monument, you may have a connection to it through your traditions, stories passed down from your elders, or from ceremonies you’ve been taught. It is important to explain your connection to Bears Ears because the way that it’s managed impacts you. Remember that every American has a stake in public lands, and many Tribes still have deep connections to public lands across the nation. The future of Tribal co-stewardship has a big impact on land and important resources like water and wildlife, but also on democracy, equality, and justice.

Keep in mind that you are writing to busy agency personnel. Your objective is to influence the BLM and USFS to consider your proposals. Approaching the situation with negativity is rarely productive. Try to acknowledge positive aspects of the draft RMP, maintain mental clarity, and calmly present factual information or your personal connections to Bears Ears. Try to appeal to land managers as people, which will help you constructively outline ways to improve the management of the Monument.

This draft Resource Management Plan is 678 pages, not including maps and other supplemental information, and we don’t expect everyone who submits a comment to know everything contained in the plan. However, if you feel up to it, we encourage you to read the document, or at least Alternative E. Alternative E is the Tribes’ choice for the best management plan for Bears Ears. If you’re going to submit a comment in support of the Tribes’ and the agencies’ preferred alternative, we encourage you to submit a comment saying that you support Alternative E. (You can also stay tuned to our socials as we share critical information regarding Alternative E.)

Clearly state what you believe is the best decision for Bears Ears, and why. If you have multiple points, organize them using bullets or numbers and use relevant headings. This approach will make your comments clear and ensure that each point is considered individually. Provide precise details and request a concrete action you are requesting from the federal agencies.

Maintaining a record of your submission is crucial in case the agency’s final document overlooks significant facts, information, or data you provided. This record could prove valuable for future reference.

Submit Your Comment Today