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Warning! No More “Bulk” Public Comments for Jeepers Warning! No More “Bulk” Public Comments for Jeepers
ModernJeepers who wheel in the 11 western states know the Sage Grouse has seriously impacted some of our recreational opportunities. However, thanks to our... Warning! No More “Bulk” Public Comments for Jeepers

ModernJeepers who wheel in the 11 western states know the Sage Grouse has seriously impacted some of our recreational opportunities. However, thanks to our organized recreation groups and land use fighters like Don Amador, Quiet Warrior Racing, common sense has been brought back into the equation to minimize the change in recreational spectrum. One thing is certain, though, when you write a letter or comment on a public document such as Sage Grouse plans, this shows you how post cards, bulk comments or “form” letters just do not work.!

The Editors

Shared from E&E News, Scott Streater.


Interest in management overhaul tests ban on ‘bulk comments’
Scott Streater, E&E News reporter Published: Thursday, August 16, 2018

A male sage grouse displays during a lek, or mating ritual, in Montana.


The Bureau of Land Management says it received at least 223,000 comments during a 90-day public comment period that ended last month on a proposal to make potentially significant changes to Obama-era greater sage grouse conservation plans. But BLM spokesman Derrick Henry said that, while the agency is still receiving some mailed comments postmarked before the Aug. 2 deadline, it appears that the vast majority of the comments counted so far were “form letters” that simply repeated the same comments or recommendations.

In an email to E&E News, Henry said the agency has counted “about 490 unique letters” commenting on the merits of proposed grouse management revisions outlined in six draft environmental impact statements (EISs) and proposed resource management plans BLM released last spring (E&E News PM, May 2). The proposed changes analyzed in the draft EISs, depending on how they’re eventually implemented, would remove some restrictions on oil and gas development, mining and other activities in the original grouse protection plans finalized in 2015 that encompass millions of acres of federal land in Colorado, Idaho, Nevada/Northern California, Oregon, Utah and Wyoming.

Public Comments Are Not Votes

“Included in the 223,000 number are many duplicates where the same letter was submitted across different states,” Henry said.

He added, “We should keep in mind, however, that comment analysis is more than a vote-tallying exercise. Comments will be weighed not as much on their number as on their substantive quality.”  The form letters fall into a category of “bulk comments” that the Interior Department has recently complained about.

Interior Secretary Ryan Zinke said last week the department wouldn’t accept such bulk comments “in any format (hard copy or electronic) submitted on behalf of others” during a 30-day public comment period on the proposed establishment of two national monuments in Kentucky (Greenwire, Aug. 9).

That ban on bulk comments also extends to public correspondence on converting the former Mississippi home of slain civil rights leader Medgar Evers into a national monument.

How BLM and Interior weigh the sheer volume of comments on the proposed grouse management changes has sparked differing views, from those who support and oppose the planned revisions.

Nada Culver, senior counsel and director of the Wilderness Society’s BLM Action Center in Denver, said a letter, even a form letter signed individually each time, “that tells the BLM to protect the greater sage grouse is substantive and important and should be weighed as such.”

Culver added: “It is disheartening to see the agency already discounting the efforts of average Americans to make their voices heard. People take the time to submit comments on how they want the BLM to manage the public lands that the agency stewards on their behalf. The agency has an obligation to listen.” But Ethan Lane, executive director of the Public Lands Council and of federal lands for the National Cattlemen’s Beef Association, said BLM is correct to handle form letters from national conservation groups differently than it does local stakeholders.

“These comment periods are not a vote, no matter how badly activists groups would like them to be,” Lane said in an emailed statement. “Public comment is critical, but substantive comments from impacted stakeholders must be respected,” he added. “Local land managers have an intimate understanding of the unique conservation challenges in their area and we hope the BLM incorporates site-specific feedback into its decision-making.”

Henry said that the public comments are important and that BLM will use them “to refine the proposed management actions and environmental analysis impacts in the EISs” before a final EIS is published this fall.

“We appreciate the submissions from our partners and interested individuals and their ongoing involvement in efforts to conserve greater sage grouse and sagebrush habitats,” Henry said. “This involvement is the basis for ongoing trust in pursuing shared goals and for the BLM to reach the best decisions about on-the-ground management responsibilities as a good neighbor in western communities.”


NOTE FROM MODERNJEEPER EDITORS: We suggest you take key issues and other talking points from your trusted motorized recreation leaders/groups and use them, but in your own words.  Get more personal about your experiences in a given area.  Let politicians and bureaucrats know your letter is from you. 


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  • Robert

    September 13, 2018 #1 Author

    sounds like the local land managers means, those that make money and make politicians money only count.


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