Want your comments on the draft environmental impact statement (EIS) to actually have an impact? Then be sure they pertain to the 1,476-page document or some part of it, suggests Andrea Huberty, USDA-APHIS project coordinator for the EIS.
All comments, however short, long or impassioned, are appreciated, she says. “I don't want to discourage people from being involved and participating in it (the comment process). Those folks who just have time to say ‘Yes’ or ‘No’? They're participating in a public process, and we appreciate their participation.”
But the most effective remarks should “be clear and concise and, most importantly for us, be relevant to the analysis in the document,” she says.
Huberty recommends reading A Citizen's Guide to the NEPA: Having Your Voice Heard, or at least the section called “How to Comment,” on page 27 of the pamphlet. It was published by the Council on Environmental Quality to explain the National Environmental Policy Act and can be viewed online at tinyurl.com/NEPAguide.
“Some may view this comment period as a type of vote-counting, but in A Citizen's Guide to the NEPA, it specifically says commenting is not a form of voting. The number of negative comments or the number of positive comments doesn't prevent or promote an action from taking place,” Huberty warns.
The NEPA pamphlet suggests focusing on the purpose and need of the proposed action — whether or not to grant non-regulated status to glyphosate-tolerant alfalfa — and the alternatives considered in the EIS, especially the assessment on environmental impacts.
“I think for those who are opposed to it, general comments that say an action will have ‘significant environmental effects’ doesn't help us, because it doesn't say how — it doesn't say how we missed the boat in the analysis if that person feels that we did.”
Those who comment in favor of deregulation could be specific in telling why they believe in it. “It would be helpful if they say, ‘We looked at this section, and we agree because of these reasons. We agree with the analysis because of this.’ Relating their comments back to the analysis that's on hand, either pro or con — both things will help us,” Huberty says.