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Comment Coach

"A single, well-written comment can have more impact than a thousand form letters"

Hi folks! Here you will find the best tips on writing a comment to get the attention of decision makers, and make them take notice of what you have to say.

To get their attention, you do not need to be an expert writer- just a US citizen with a desire to be heard and a plan on how to comment. The fact is, a single, well written comment can have more impact than a thousand form letters.

By commenting strategically, you can influence outcomes and play a role in how public officials govern. Your comment ensures more prudent decisions on the use of your tax dollars, helps officials spot missing issues, and directs future policy.

The writing tips are presented in a 3-part format: Before You Begin, During the Writing Process and After You Finish. Last are three generally useful Final Notes.

Identify

  • Identify areas of specific interest to you and then find notices related to those areas using a keyword, zip code or Track Number search.
    • Note! Make sure the comment period is still open for the notice you've chosen.
  • Identify the end date for a comment period, because most agencies do not accept comments after 11:59 pm on the comment end date.
  • Identify your goals in addressing the issue; this will help with writing your comment.

Read

  • Read the notice itself, with a keen eye for what may be missing and what it addresses.
  • Read to see whether you have questions or do not understand a part of the notice or a related document. If so, ask for help from the agency contact listed in the notice.

Review

  • Review laws related to the notice you chose.
  • Review background material related to the notice subject.
  • Review the supplemental material provided (if any).
  • Review other comments. Other people's comments often trigger points you missed and may identify allies and/or adversaries.

Compare

  • Compare what you have said to what others say on the issue.
  • Compare their data against other known data, and if the conclusions reached are supported by the data.
  • Compare the document against itself by verifying it is internally accurate and without discrepancies between parts of the document.

Stick to the Facts!

  • Everyone has an opinion, but only facts can back it up; make sure your comment is substantive.

Comment on the law!

  • Demonstrating that the law requires a certain change of course is a compelling argument. Since agencies are legally bound, a legal minefield arises if an action is inconsistent with applicable laws.
  • To get the attention of the agency, you can and should quote the statute in your comments.
  • Any violation of law is a powerful comment. A violation of a legal requirement can delay or permanently disrupt the proposed action.

Comment on the facts!

  • If you believe that information in a notice is wrong, ambiguous, or deficient, or were not given appropriate weight in the decision - comment on the facts!
  • Try to distinguish relevant facts from those that are not.
    • For example, commenting on how much you enjoy camping in a wilderness area may be important to you, but it's not a relevant fact. But the potential of a project to destroy the wilderness values of a designated area is a relevant fact that may trigger legal safeguards!

Comment on the process!

  • At times it may be useful to comment on the process as failing to meet procedural requirements. This can raise legal red flags. Process related comments fall into four categories:
    • Key people were not involved in creating the proposal;
    • Insufficient notice or opportunity for involvement;
    • Inadequate time allowance for review; or
    • Excluded important materials from the record.

Comment on the impact!

  • Comment on the positive or negative impact on you.
  • Comment on the economic effects of proposed actions.
    • Note! Quantitative or qualitative data are especially helpful.

Understand your audience!

  • There's a real person, an agency employee reading your comment that may be halfway through reading hundreds more just like yours.
  • Stay Civil
    • Note! Your comment is much more likely to be taken seriously if you avoid profanity and insults and stick to writing a well reasoned, factually based argument from your point of view.
  • Get a Little Personal
    • Be real, and write from the heart. If you have a personal story, share it. Putting a human face to an issue helps us understand better. Use phrases like, "As a teacher," "As a parent of two," or "As an attorney."
  • Design the Comment for Easy Use.
    • Chunk information, use subheadings, and organize details in bulleted lists or paragraphs or graphics.
    • Avoiding dense disorganized text. People with time pressures must comprehend your comments. Make them easy to find and use.
  • Be Solutions Oriented.
    • If you disagree with a proposed action, suggest alternatives such as mitigation, changes in timing, offsets, conditions or exemptions (including not taking the action at all) and explain how the alternative might meet the same objective or be more effective.
  • Don't spend time thanking "them" for the opportunity to comment. They're required to receive comments and, being pressed for time, would rather you use your words to make your comment.

Stick to the 4 "C's"

  • Clear.
    • The comment should have a single message that can be found quickly, is understood easily, recognized as relevant, and useful. Give specific examples to clarify your points using real-life or hypothetical examples to create mental images to emphasize your point.
  • Correct.
    • The information contained in the comment is accurate.
  • Concise.
    • The comment presents only what's necessary, using the fewest words possible with aids for comprehension.
  • Credible.
    • The information in the comment can be trusted, traced and used with confidence.

Represent Your Authority

  • Comments represent a type of participation and power. Accurately state your role and status - a citizen with an opinion, an expert with an opinion, or maybe a spokesperson for an organization.
  • Identify credentials and experience that may distinguish your comments from others. If you have relevant personal or professional experience, say so.

Address a Specific Audience - About Specific Issues - At the Right Time

  • State if you're for or against what is being proposed.
  • For those reviewing your comments, time is scarce. Save thinking time for them by specifying your intended recipient and subject.
  • Make your point up front. The first sentence of each paragraph should be a main point.
  • Timing matters, largely due to the nature of policy cycles. Agendas change. Stuff happens. Be explicit in your relevance and purpose to get timely attention.
  • If you're commenting to have a sentence or document re-worded, provide the specific replacement language if you know exactly what you want said.
  • If a Notice raises many issues, do not feel obligated to comment on every one - select the issues that concern you the most, affect you the most, and/or you understand the best.

Use Logical Arguments and Cold, Hard Facts

  • Comment with reason and disagree without being disagreeable. Agencies look for sound science and reasoning in comments. Using substantive data, facts and/or expert opinions for support will more likely impact the outcome.
  • Provide persuasive reports, studies, or articles not used in the process, and include citations with author and date.
  • Explain the pros and cons and trade-offs of your position. Respond to other viewpoints with facts and sound reasoning.

Use Active and Avoid Passive Sentences.

  • For example, an active sentence is: "The proposed project would destroy more than 50 acres of habitat for the gray wolf" versus a passive sentence: "More than 50 acres of gray wolf habitat would be destroyed by the proposed project"!
  • Passive sentences tend to be more confusing and weaker. Plus, the active sentence directly indicates the actor or responsible party; in the above case, the "proposed project" is to blame.

Follow Proper Procedures

  • Make sure you follow all procedures the agency issuing this specific notice require for commenting on this specific notice.
  • Not only may procedures differ agency to agency, they may differ notice to notice from the same agency.

Address the Intended Recipient

  • Each notice is issued by a specific agency; make sure your comment addresses that agency.
  • If the notice itself says to direct all comments to a specific person, make sure you address that person.

Follow-up on Your Comment

  • Your comment may impact the proposed action, so make sure you follow up to see if changes occurred or if your comment got a reply.
  • Your comment may influence others to change their opinion, so follow-up on our site to see the impact your comment has had.
  • Industry, labor, political parties, and activist groups often encourage their members to use form letters to voice their opposition or support of a proposed action. Some folks mistakenly believe submitting a form letter constitutes a "vote" on the issue. While public support or opposition matters, agencies act based on sound reasoning and scientific evidence, not votes.
    • Remember, a single, well-written comment can have more impact than a thousand form letters!
  • Public comment, sometimes called "vox populi" was a core tenant of the constitutional democracy elaborated in the American Revolution, and thinkers such as Franklin, Jefferson - and Thomas Paine - associate public comment with the rejection of closed government decision-making in favor of open government. The tradition of the New England Town Hall is rooted in this early American movement.
  • The information and writing tips provided in Comment Coach serves as a guide; it is not intended and should not be considered as legal advice. Please seek counsel from a lawyer is you have legal questions or concerns.