Constructing Effective Comments Under NEPA

[Saph]

I came across this document that was published by the Oregon Farm Bureau.  
Constructing Effective Comments Under NEPA

It applies to any of us that would like to comment on upcoming Land Use Plans.  It is very thorough but here is a brief summary:

Use Headings

•  Go section by section, and use descriptive headings.
  
•  For example, "The EIS underestimated the effects of the action alternatives on local communities." 
  

Focus on cause and effect 

•  If you allege that the EIS does or does not do something,
  clearly connect the dots.
  
•  For example, "The EIS underestimated the effects of the action alternatives on local communities because it failed to account for local investment in farmland. On my farm alone, I have invested over $_____ in improvements and structures that would be impacted by the transmission line. The EIS does not account for these impacts." 
  

Provide as Much Factual Support as Possible. 

• If you have support for your statement, cite to it! Whether it's news articles, scientific articles, or statements you've heard made by agency staff or others. 
  
• The more factual support you can provide, the more seriously your comments will be taken. 
  

Point out Inadequacies.

• Point out areas where the EIS is not clear or is missing necessary information. State clearly that you were not able to analyze potential impacts of the decision due to the lack of information. 
  

Focus on Environmental and Economic Impacts Separately.

•  While the agencies are directed to consider the economic impacts of their decisions, environmental impacts tend to weigh more heavily in a NEPA analysis.
  
•  However, economic impacts are important and should be stated up front and clearly.
  
•  Environmental impacts should be separately addressed, and should contain as much support as possible from outside studies, anecdotal experience, or other reliable sources (more on this to come...) 
  

Do not rant.