Current Comment Periods:
Comment period: Feb 19, 2026- March 23, 2026
RE: Scoping Comments — Notice of Intent to Revise Resource Management Plans for Northwestern and Coastal Oregon and Southwestern Oregon
Dear Bureau of Land Management Oregon/Washington State Office:
I am submitting these comments in response to the BLM's Notice of Intent to revise the Northwestern and Coastal Oregon and Southwestern Oregon Resource Management Plans, published February 19, 2026.¹
I. Scope and Scale
The proposed revision covers approximately 2,460,000 acres across 17 Oregon counties and signals a fourfold increase in annual timber harvest — from 250 million to 1 billion board feet per year.² The O&C Act's sustained-yield mandate does not override FLPMA or NEPA, both of which require rigorous environmental review and balanced multiple-use management.³ Any revised RMPs must reflect the full range of public land values, including watershed protection, wildlife habitat, and recreation.
II. Public Participation Deficiencies
The BLM's 2016 RMP revision involved years of public workshops, tribal consultations, and open houses.⁴ This NOI explicitly states the BLM will hold no public meetings during scoping⁵ — a significant and atypical departure from prior practice. The 32-day comment window is wholly insufficient for a proposal of this scale. The BLM is requested to schedule a minimum of five public scoping meetings across the planning area, offer virtual participation options, and extend the comment period by at least 60 days. Additionally, DOI's recent conversion of binding NEPA regulations to non-enforceable guidance⁶ and ongoing litigation challenging the use of emergency authority to fast-track approvals⁷ raise serious concerns about the rigor of the environmental review that will follow.
III. Wildfire-Logging Science
Wildfire risk does not justify a fourfold increase in commercial timber harvest. Peer-reviewed research supports targeted removal of small-diameter trees and surface fuels combined with prescribed burning as effective fire risk reduction.⁸ Commercial logging of large, mature trees does not replicate these outcomes and may increase fire risk by opening the canopy, drying surface fuels, and accumulating slash.⁹ The BLM must ensure wildfire prescriptions are grounded in site-specific science and not conflated with commercial timber objectives. The EIS must also analyze carbon storage impacts, as O&C lands rank among the most carbon-dense temperate forests on Earth.¹⁰
IV. ESA Compliance
The planning area contains critical habitat for the northern spotted owl, marbled murrelet, and Oregon Coast coho salmon — all federally listed species.¹¹ Formal Section 7 consultation with USFWS and NMFS must be completed before any revised RMPs are finalized.
V. Requested Actions
The BLM is respectfully requested to: extend the comment period by 60 days; hold public scoping meetings across the planning area; conduct a full EIS without abbreviated procedures; ground all fire management prescriptions in peer-reviewed science; analyze greenhouse gas and carbon storage impacts; and complete ESA Section 7 consultation prior to finalizing any RMP revision.
These comments are submitted for the administrative record.¹²
Respectfully submitted,
[Name]
FOOTNOTES
¹ 91 Fed. Reg. 33, Feb. 19, 2026. Docket No. 2026-03290. ² Id. ³ 43 U.S.C. § 1701 et seq. (FLPMA); 42 U.S.C. § 4321 et seq. (NEPA); Headwaters, Inc. v. BLM, 893 F.2d 1012 (9th Cir. 1989). ⁴ 86 Fed. Reg. 2968 (Jan. 14, 2021). ⁵ BLM NOI, supra note 1. ⁶ CEQ, NEPA Implementing Regulations Revisions Phase 2, 88 Fed. Reg. 49924 (July 31, 2023). ⁷ Coalition of States v. U.S. Dept. of the Interior, No. [2026] (D.D.C. filed Jan. 2026). ⁸ Prichard, S.J. et al., Ecological Applications, 2020; Lydersen, J.M. et al., Ecological Applications, 2014. ⁹ Zald, H.S.J. & Dunn, C.J., Ecological Applications, 2018; Odion, D.C. et al., PLOS ONE, 2014. ¹⁰ Law, B.E. et al., Proceedings of the National Academy of Sciences, 2018. ¹¹ 16 U.S.C. § 1531 et seq.; USDI FWS, Northern Spotted Owl Recovery Plan, 2011; ODFW, Oregon Native Fish Status Report, 2022. ¹² Comments due March 23, 2026 via eplanning.blm.gov (Project No. DOI-BLM-ORWA-0000-2026-0001) or by mail to BLM OR930, 1220 SW 3rd Ave, Portland, OR 97204.
Comment Period Dates: Feb 6, 2026- March 9, 2026 11:59 PM EST
Script:
Re: Proposed Revisions to the Project-Level Predecisional Administrative Review Process (Feb. 6, 2026)
Submitted to the United States Forest Service
I submit this comment in opposition to the proposed revisions to the Project-Level Predecisional Administrative Review Process under 36 C.F.R. Part 218.
The predecisional objection process is a critical procedural safeguard embedded within the Forest Service’s implementation of the National Environmental Policy Act (NEPA) and the Healthy Forests Restoration Act (HFRA). It ensures that individuals and entities who have participated during scoping and comment periods retain a meaningful opportunity to seek administrative review before a final decision is implemented.
The proposal to reduce public comment periods by approximately half substantially undermines informed participation. Many project-level NEPA analyses include:
These documents frequently span hundreds to thousands of pages and require technical expertise to evaluate. Curtailing comment periods restricts the ability of Tribes, local governments, scientists, rural stakeholders, and nonprofit organizations to provide substantive, evidence-based comments.
Courts have consistently held that NEPA’s procedural mandate requires agencies to provide a meaningful opportunity for public participation. A compressed review window increases the risk that the administrative record will be incomplete, raising both procedural vulnerability and litigation risk.
Efficiency achieved through procedural compression is not durable efficiency.
Many project-level decisions involve vegetation management in mature and old-growth stands. Old-growth forests provide:
Shortened review periods reduce the likelihood that independent ecological experts can adequately assess whether projects comply with forest plan standards, old-growth retention requirements, or evolving agency direction on mature and old-growth conservation.
Once old-growth is logged, it cannot be administratively restored. The objection process is often the final checkpoint before irreversible loss.
Project-level actions frequently affect habitat for sensitive and listed species. Adequate review time is necessary to evaluate:
Compressed timelines may reduce the quality of public scientific input regarding species viability, connectivity corridors, and ecosystem resilience.
Wildlife impacts are cumulative and long-term. Administrative review must reflect that reality.
The agency often justifies expedited timelines on the basis of wildfire risk reduction. However, wildfire science is highly site-specific. Public review ensures that:
Rushed review does not inherently produce safer forests. Durable wildfire resilience requires careful, science-based planning and public scrutiny.
The objection process strengthens agency decision-making. Reducing comment periods weakens the administrative record, diminishes public trust, and increases legal vulnerability.
I respectfully request that the Forest Service withdraw the proposed revisions and maintain meaningful, accessible opportunities for public participation consistent with NEPA and governing regulations.
Public lands are held in trust for present and future generations. The administrative process should reflect that responsibility.
Comment Period Dates: Jan 15, 2026 - Feb 17, 2026 at 11:59 PM EST
Script:
I am writing in opposition to the Environmental Protection Agency’s proposed revisions to the Clean Water Act (CWA) Section 401 Water Quality Certification regulation. Section 401 is a cornerstone of the Clean Water Act’s cooperative federalism framework, providing states and authorized Tribes with the authority to ensure that federally permitted activities comply with water quality standards before pollution occurs. This preventive function is essential to protecting drinking water sources, wetlands, fisheries, and downstream communities from irreversible harm.¹
The proposed rule would significantly narrow how states and Tribes may exercise their Section 401 authority by restricting the scope of review, redefining what constitutes a complete certification request, and limiting the conditions that certifying authorities may impose.² While EPA characterizes these changes as procedural clarifications, their practical effect would be to constrain state and Tribal oversight and accelerate permitting timelines at the expense of water quality protection. This approach conflicts with the Clean Water Act’s express purpose “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.”³
Section 401 has historically served as one of the most effective tools for protecting wetlands and headwater streams that are critical to downstream water quality, flood mitigation, and ecosystem function. Weakening this authority risks increasing reliance on post-hoc cleanup rather than prevention, shifting long-term environmental and financial burdens onto states, Tribes, and taxpayers. Environmental organizations and legal experts have warned that the proposed changes would reduce meaningful review of projects such as pipelines, hydropower facilities, and other infrastructure with well-documented risks to water resources.⁴
Of particular concern is how this proposal continues a broader pattern of undermining Tribal authority through regulatory action. Tribes are sovereign governments, not stakeholders, and many hold treaty-reserved rights to clean water, fisheries, and aquatic resources. Federal agencies have a legally enforceable trust responsibility to protect these rights. Any rule that limits the ability of Tribes to meaningfully review, condition, or deny certifications for projects affecting their waters or treaty resources undermines binding treaties and long-standing federal obligations.⁵
EPA has previously recognized that robust Tribal participation in water quality certification is essential to honoring Tribal sovereignty and protecting Tribal waters.⁶ Rolling back or narrowing this authority under the guise of efficiency erodes trust, weakens environmental justice protections, and disproportionately impacts Tribal nations and downstream communities that often bear the greatest consequences of water pollution.
For these reasons, EPA should withdraw or substantially revise the proposed rule to preserve strong state and Tribal authority under Clean Water Act Section 401. Protecting clean water requires honoring the statute’s preventive intent, respecting Tribal sovereignty and treaty rights, and ensuring that economic development does not come at the cost of irreversible harm to waters and communities.
Previous Comment Periods:
Comment Period: Nov 24, 2025- January 23, 2026
Script:
Re: 11th National OCS Oil and Gas Leasing Draft Proposed Program (MAA104000)
I am writing to oppose the proposed expansion of oil and gas leasing across the Outer Continental Shelf as outlined in the 11th National OCS Leasing Program Draft Proposed Program.
I care deeply about our coastal and marine environments — not just as abstract resources, but as living systems that support wildlife, coastal communities, fisheries, and ways of life. This draft proposal feels like a step backward at a time when we should be moving decisively toward protecting these places, not reopening them to long-term fossil fuel development.
The existing offshore leasing program includes just three lease sales in the Gulf of Mexico. That limited scope reflected an understanding that offshore drilling carries real risks and long-lasting consequences.
The 11th Draft Proposal is fundamentally different. By considering up to 34 lease sales across Alaska, the Pacific, and the Gulf, it dramatically expands where offshore drilling could occur and how much of our shared ocean is put at risk. Once these areas are included at this early stage, it becomes extremely difficult to remove them later.
New offshore oil and gas leases are not short-term decisions. They can lead to drilling and production for 30 years or more, locking in fossil fuel use well past the point when climate science tells us we must be rapidly reducing emissions.
Leading scientific bodies have been clear that new oil and gas development is incompatible with avoiding the worst impacts of climate change. Approving additional offshore leasing now ignores that reality and places future generations in an even deeper climate crisis than the one we already face.
Offshore oil and gas development comes with unavoidable risks: oil spills, seismic testing that harms marine mammals, and chronic pollution that degrades ocean ecosystems. We have seen the consequences before, most notably with the Deepwater Horizon disaster, which caused lasting damage to marine life and coastal economies.
Expanding leasing into new regions — especially places like the Pacific Coast and Alaska — puts ecosystems and communities at risk that have long depended on clean water, healthy fisheries, and thriving tourism. These risks are not worth taking, especially when cleaner energy alternatives are readily available.
Under the Outer Continental Shelf Lands Act, BOEM is required to balance energy development with environmental protection, existing ocean uses, and the long-term public interest. Casting such a wide net for offshore leasing fails that test.
At a time when:
It makes little sense to expand offshore oil and gas leasing into new and sensitive areas.
I urge BOEM to:
At a minimum, BOEM should reconsider whether expanding offshore leasing is consistent with climate science, environmental protection, and the public interest it is charged with serving.
This draft proposal will shape offshore energy decisions for decades. I believe we owe it to future generations to protect our oceans, coastlines, and climate — not to further entrench our reliance on fossil fuels. I respectfully ask BOEM to change course and pursue a more cautious, responsible approach.
Thank you for the opportunity to comment.
Sincerely,
[Your Name]
[City, State]
Comment period: 11/21/25-11/22/25
Script:
Public Comment on Proposed Rule: “Endangered and Threatened Wildlife and Plants; Regulations for Designating Critical Habitat”
Docket ID: FWS-HQ-ES-2025-0048; FXES11110900000-256-FF09E23000
Position: Oppose the Proposed Rule
Thank you for considering public input on this proposal. I am submitting this comment because the ESA is one of the most important environmental protections in the United States, and the changes outlined in this rule would significantly weaken its ability to prevent extinction.
1. The proposal ignores well-established science on fragmentation and extinction risk
The scientific consensus is clear: habitat fragmentation is one of the strongest drivers of biodiversity loss. A global synthesis found that fragmentation reduces species richness, diminishes biomass, and disrupts ecological functions at every scale—from insects to large mammals.¹
Another peer-reviewed study of 4,000 terrestrial mammals demonstrated that fragmentation alone significantly increases extinction risk, even when habitat area remains constant.²
By restricting critical habitat to areas currently occupied, the rule invites more fragmentation, carving species into smaller, more vulnerable populations.
2. Species’ current ranges do not reflect what they need to survive in a warming climate
Climate change is already shifting species’ distributions, often pushing them into shrinking climate refugia. A 2025 study of the Organ Mountains Colorado Chipmunk showed a dramatic loss of lower-elevation habitat, forcing the species into cooler, isolated pockets.³ These are not hypothetical future impacts; they’re happening now.
If critical habitat is limited to "current use" only, species will not have the room they need to move, adapt, or survive warming temperatures.
3. Protected lands alone cannot support species movement
A major global analysis found that existing protected areas do not form a connected network capable of supporting species’ climate-driven range shifts.⁴
Corridors, stepping-stone habitats, and unoccupied patches are essential for resilience. The rule’s new restrictions on unoccupied habitat would cut off climate migration pathways at the exact moment they are becoming most critical.
4. Natural disasters increase extinction risk — species need backup habitat
A 2024 peer-reviewed study mapped species’ vulnerability to natural hazards and found that many already-threatened species live in high-risk zones where one large hurricane, wildfire, or cyclone could eliminate the entire population.⁵
Critical habitat rules must account for recovery space—not just current range.
5. Recovery requires protecting unoccupied habitat for the future
Unoccupied habitat often serves as future range, recolonization zones, or climate refugia. Conservation researchers and environmental biologists emphasize that protecting only the habitat species currently occupy is short-sighted and scientifically indefensible.⁶
The ESA was designed to protect not just survival, but recovery. This rule undermines that core purpose.
Based on overwhelming ecological evidence, I respectfully ask the Agencies to:
Withdraw this proposed rule.
Maintain the ability to designate unoccupied critical habitat without imposing restrictive tests that undermine recovery.
Ensure designations reflect future climate conditions, not only present-day occupancy.
Consider fragmentation, connectivity, disaster-risk, and long-term resilience as essential biological factors.
Uphold the ESA’s purpose: preventing extinction and enabling species to recover.
I oppose the proposed changes to how critical habitat is designated under the Endangered Species Act. The rule ignores decades of peer-reviewed science on habitat fragmentation, connectivity, climate-driven range shifts, and extinction risk. By restricting unoccupied habitat, redefining harm too narrowly, and prioritizing economic impacts over biological needs, this proposal undermines species survival and recovery.
Footnotes / Peer-Reviewed Citations
¹ Haddad et al. 2015. Habitat fragmentation and its lasting impact on Earth’s ecosystems. Science Advances. doi:10.1126/sciadv.1500052
² Crooks et al. 2017. Quantification of habitat fragmentation reveals extinction risk in terrestrial mammals. PNAS. doi:10.1073/pnas.1705769114
³ Jacobson & Frey 2025. Climate-driven niche reduction in the Organ Mountains Colorado Chipmunk. Journal of Mammalogy. doi:10.1093/jmammal/gyaf059
⁴ Parks et al. 2023. Protected areas not likely to serve as stepping-stones for species undergoing climate-induced range shifts. Global Change Biology. doi:10.1111/gcb.16629
⁵ Tekwa et al. 2024. A global map of species at risk of extinction due to natural hazards. PNAS. doi:10.1073/pnas.2321068121
⁶ Center for Biological Diversity. 2015. Biodiversity on the Brink: The Role of Unoccupied Habitat in Species Recovery.
Public Comment Period: Nov 12- Dec 12, 2025
Script:
I am strongly opposed to any move toward commercial leasing for deep-sea mineral extraction offshore the Commonwealth of the Northern Mariana Islands. BOEM is considering opening more than 35 million acres of seafloor—much of it in extremely deep, fragile, and poorly understood ecosystems—to an industry that even the Congressional Research Service says lacks adequate baseline science. We do not fully understand the biodiversity, ecological functions, or long-term consequences of disturbing these habitats, and recovery in the deep sea can take centuries, if it happens at all. Proceeding anyway is irresponsible.
The justification that this is about “critical minerals” does not outweigh the risks to the Chamorro and Refaluwasch communities whose cultural ties and subsistence relationships to these waters are routinely ignored in federal resource-extraction decisions. This process is backwards: you’re asking the public for input before providing complete environmental data, before meaningful community consultation, and before any true accounting of ecological, social, and economic harm. That is not informed decision-making—it’s laying the groundwork for extraction while pretending the impacts are unknown or manageable.
At a time when ocean health is declining, climate pressures are intensifying, and biodiversity is collapsing globally, opening up one of the least-studied marine regions on Earth to mining is unacceptable. BOEM must halt any actions toward leasing until comprehensive, peer-reviewed baseline science exists, full community consent is obtained, and transparent impact analyses are completed and publicly available. Anything less is a failure of stewardship and an abdication of responsibility.
Sources:
– BOEM CNMI Activities Overview (BOEM, accessed 2025)
– Congressional Research Service, Deep Seabed Mining: Regulatory and Environmental Considerations (2024)
– Deep-Sea Mining Ecological Impact Overview (summarized via open literature incl. DSM reviews)
CLOSED COMMENTING PERIODS
Public Comment Opposing ConocoPhillips and Other Entities’ Test Drilling and Seismic Studies in Alaska’s Western Arctic
Public Comment period: Nov 10- Nov 17, 2025
Script:
I strongly oppose ConocoPhillips and all other entities pursuing test wells, seismic studies, or any form of fossil fuel exploration in Alaska’s Western Arctic. This region is one of the last intact and functioning ecosystems on the planet — a living system that supports caribou herds, migratory birds, fish, and communities that have relied on these lands for countless generations. To fracture, blast, and drill this fragile landscape for short-term corporate profit is nothing short of ecological vandalism.
The idea that our nation should continue pillaging ecosystems for Arctic fossil fuels—at a time when climate change is accelerating faster than predicted—is indefensible. Extracting and burning these reserves will only worsen the climate crisis that is already melting permafrost, collapsing coastlines, and threatening the very habitat these corporations claim to “minimize impact” on. There is no version of oil development in the Arctic that is compatible with a livable planet.
Equally unacceptable is the shortened public comment period for a project of this magnitude and consequence. Limiting public participation in decisions that will shape ecosystems for generations undermines democratic process and silences the voices of those who care deeply about the health of our environment. The public deserves full transparency, ample time for review, and meaningful engagement—not a rushed timeline that caters to industry interests.
The Western Arctic is not a resource colony for extraction; it is a vital, interconnected landscape that holds immense ecological, cultural, and climatic value. I urge the agencies overseeing this proposal to reject all new seismic exploration, test drilling, and related fossil fuel development activities in this region. Protect what remains wild—do not sacrifice it for profit.