Wild Horse Education

Will bulk comments be banned from “comment periods?”

“Bulk Comment” Ban in BLM Future?

What is a bulk comment?

Bulk comments are comments sent in a “click and send,” or copied and pasted into an individual email account, off an orgs website. These also include adding your name to an orgs letter.

The public often uses these letters to express an agreement with a statement made in process by an organization. Most Americans do not have time to research, look for experts in a field, new techniques.

Bulk Process

Sometimes bulk comments are appropriate in process, sometimes they are not.

An example of appropriate bulk comments are those made to your representatives in Congress; these are your representatives representing your local voice. Pressure on legislators through the use of information found in “bulk comments,” like the shrinking of a National Monument, is more than simply an appropriate action, it’s vital.

On an EA for a roundup? no. A support letter the org uses if it litigates the roundup? yes. A roundup EA analysis the impact of removing wild horses, it does not analyze management. Those documents are supposed to come before a roundup EA. In many instances the underlying frame was not fully built according to policy. It is a long standing deficit.  In wild horse advocacy we often see a deep misunderstand to what comments are appropriate at which part of process. That however, is another topic.

The purpose of comments on an action is to point out harms, new info and failures in analysis or process.

How are these letters used?

These letters have several purposes for the organizations that create them. It demonstrates their position has public support. Some use them simply to build larger mailing lists or for press releases. Some use them if an issue has to go into a courtroom to demonstrate that the position the org has taken is of “public interest.” Some use them for all of the stated reasons.

Public interest is a key component of any legal argument for decisions made in land management; it’s public land. However the validity of a legal argument is not “made or broken” based on the number of signees on a petition, it simply gives the person creating the argument an additional reason to bring it into the judiciary.

Banning Bulk Comments?

READ MORE https://www.publichorses.com/comments-excluded-news/


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Categories: Wild Horse Education