Should Numbers Count?

Over 7,000 people have signed an Earthjustice petition at  The Forest Service has always insisted that commenting on NEPA documents is not a numbers game.  Should it be?  The agency insists that substantive comments carry more weight that mass mailings.  Should they?  What do these 7,000 signatures really mean?




U.S. Forest Service



For nearly 30 years, some of the most prized and important waters and wildlife habitats have been protected by a federal rule that directs the management of our National Forests. But all of that could change with a proposed rule change that would leave wildlife and waters in peril.

Tell the Obama Administration and the Forest Service to strengthen – not weaken — this rule so that it guarantees protections for our National Forests.

In the United States, there are 155 National Forests, covering more than 190 million acres. National forest lands are the single largest source of drinking water in the nation, providing fresh water to some 124 million people. In addition to giving many of us the water we drink, our forests also are cherished grounds of our nation’s outdoor legacy.

Millions of Americans visit our National Forests each year to enjoy world-class hunting, fishing, camping, hiking, and recreation activities, and many millions more rely on them for safe drinking water. Don’t let the Administration give up these precious resources by weakening the federal regulations.

Let the Administration and Forest Service know that we won’t stand by as federal rules damage our National Forests.

6 thoughts on “Should Numbers Count?”

  1. When I used to sit on a city council we were always quick to point out that neither gathering signatures nor showing up “en masse” ought to sway the council’s votes on matters. Same here.

    PS.. Jim, I fixed the hyperlink to the “petition letter” that was broken in your post. Just so you know.

    • What should “sway the vote”? Deliberation as part of Deliberative Democracy (Wikipedia link)! Interest groups play the “signatures” game because they can “sway” votes or decisions, but that is not to say it is the best way. Problem is, IMO, there is too little deliberation in our system, and too much hype, hyperbole, “herding” of groupies, and so on. A good little primer on the problem is Neil Postman’s Amusing Ourselves to Death: Public Discourse in the Age of Show Business (Wikipedia link). Postman’s account builds on earlier work in Aldous Huxley’s nonfiction Brave New World Revisited (Wikipedia link).

      • Dave- I really liked your Deliberative Democracy link, so I linked to an example..America Speaks and was intrigued by their idea of:

        21st Century Town Meeting

        AmericaSpeaks’ 21st Century Town Meeting is intended to create engaging, meaningful opportunities for citizens to participate in public decision making. This process attempts to update the traditional New England town meeting to address the needs of today’s citizens, decision makers and democracy. Unlike most of New England’s town meetings, however, it is not a formal legislative body, and therefore none of the decisions are binding.

        The 21st Century Town Meeting marks a departure from traditional public participation methods, such as public hearings. The 21st Century Town Meeting focuses on discussion and deliberation among citizens rather than speeches, question-and-answer sessions or panel presentations. The purpose of the Town Hall Meeting is to gather diverse groups of citizens who will participate in round-table discussions (10-12 people per table) and deliberate in depth about key policy issues. Each table discussion is supported by a trained facilitator to keep participants on task. Participants receive discussion guides that present further information about the issues under consideration.

        Technology collects the individual table discussions and the results are compiled into a set of collective recommendations. Each table submits ideas using wireless groupware computers and each participant can vote on specific proposals with keypad polling. These two pieces of technology allow for real-time reporting and voting. Results from discussions are presented to participants within minutes and polling results within seconds. The entire group votes on the final recommendations to submit to decision makers. Before the meeting ends, results from the meeting are put into a report, which is distributed to participants, decision makers and the news media as they leave.

        I wonder if these concepts, plus some kind of virtual table discussions, could be incorporated into a planning rule or plans?

  2. Yes, I think substantive comments should carry more weight. For one thing, many of these public sign-ons are either too vague to be helpful (your rule is bad for wildlife) or make assertions that are untrue, or sometimes both. The one above example is fairly good in this regard, it is clear what EJ wants to change.

    Nevertheless, it seems like the choice is “clickin’ with a group I generally trust'” versus “thinkin’ at least a little for myself”. Any good public policy should take into account the comments that reflect “thinkin.” Of course, many letters are simply reworded a bit from a general statement, but comment has never intended to be a vote.

    Note: this is just my personal opinion and not an official statement ….

    I also noticed this:

    This will likely lead to decisions based more on politics than science.

    Scientists (’cause after all, “science” wouldn’t determine policy, scientists would- an important point) as decisionmakers

    Scorecard- Scientists as drivers..
    NY Times 1
    Wilderness Society 1
    Earthjustice 1


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