Farm Bureau Minute
by Mike White, President, New Mexico Farm & Livestock Bureau
Words Matter
What do you think of when you hear the word “comment?” Such a mild word, seems harmless, like having a comment on something doesn’t really matter.
A passing expression of opinion that doesn’t have a lasting impact.
But to the Bureau of Land Management, the Forest Service, the United States Fish and Wildlife Service, and all governmental agencies whether State or Federal, a comment is a big deal. Submitting a comment is your only opportunity to voice your opinion about proposed actions by governmental agencies. Comments are so important to us as food producers, members of rural communities or as just a citizen they should be renamed to “protests” or “objections.” These are stronger words that carry emotion and meaning. It’s easier to motivate someone to protest an issue because that means they are taking it personally.
Maybe that’s why the bureaucracy chose the word comment so as not to raise your ire. So that you wouldn’t get fired up. But agriculture needs you to be fired up.
No matter where you live in New Mexico there are actions pending by so many government agencies that negatively impact your farm, ranch or local community and your ability to pass it down to your family that there is not room enough in this column to list them all. Whether it is the proposed expansion of wolf habitat, road closures in the forest, BLM resource management plans, or potential pipeline projects, there is always an issue open for comments.
What is the commenting process? According to “A Citizen’s Guide to the NEPA” (National Environmental Policy Act) found here: Guide_Dec07.pdf
“Commenting may be the most important contribution from citizens.” Comments are the mechanism by which you as an individual or agency qualify for “standing” when you disagree with a chosen proposal and wish to voice your opinion as to why a particular law or regulation effects you, your business or industry.
The guide notes that comments “that are solution oriented and provide specific examples will be more effective than those that simply oppose the proposed project. Comments that contribute to developing alternatives that address the purpose and need for the action are also effective. They are particularly helpful early in the NEPA or commenting process and should be made, if at all possible, during scoping, to ensure that reasonable alternatives can be analyzed and considered early in the process.”
Furthermore “In drafting comments, try to focus on the purpose and need of the proposed action, the proposed alternatives, the assessment of the environmental impacts of those alternatives, and the proposed mitigation. It also helps to be aware of what other types of issues the decision maker is considering in relationship to the proposed action.”
However, “Commenting is not a form of “voting” on an alternative. The number of negative comments an agency receives does not prevent an action from moving forward. Numerous comments that repeat the same basic message of support or opposition will typically be responded to collectively. In addition, general comments that state an action will have “significant environmental effects” will not help an agency make a better decision unless the relevant causes and environmental effects are explained.”
Commenting seems complicated, but it is required for us to have a say in the activities of federal and state agencies. In order to ensure the success of future agricultural endeavors, and to make sure your family farm/ranch stays in the family, we need our NMF&LB members to be involved, engaged and vocal.