GNEP Environmental Impact Statement Comments

I recently got my hands on an anti-nuclear activist's comment submitted to the Department of Energy on GNEP's environmental impact statement. It serves as an example of a few things to do when writing public comments, as well as some things not to do.

First, don't talk about morals and ethics; talk about the legal and public relations implications of the proposed action. Morals and ethics are nice, but being immoral or unethical doesn't have an immediate negative effect on the decision-makers. Being sued or inciting a riot does, and a comment must make clear that the proposed action is either illegal or will result in negative political consequences.
If the proposed action is legal and you still don't like it, you have two options. If you have enough money, lawyers are extremely creative and can concoct an admissible contention from almost anything, and trials/settlements cost the opponents money even if you lose. If you have no money and a lot of people, get about 1,000-1,500 of them to submit near-identical comments threatening protests and media activity. And above all, be prepared to follow through if they go ahead with the proposed action; you can't be caught bluffing. If you are, that's the end of your credibility.

Do not assume that they have received "expert analyses" and that you only have to second them. Know the most important points of those analyses and echo them as though you didn't know about the expert analyses--it's much more impressive to whatever bureaucrat reads the comment if they think that there's a huge groundswell of opposition for diverse, original reasons instead of three guys and their 1,500 foot soldiers.

Don't ask them to follow the procedure. They either will follow the procedure or won't, and the only thing you can do is threaten negative consequences if they don't (or do, if you don't want them to follow the procedure).

Don't include conspiracy theories. Preferably, don't originate them or subscribe to them, but don't try to analyze people's motives or do a power structure analysis, either. They don't care about that. Again, they care only about negative consequences to them politically, legally, and financially if they proceed. If you don't want them to do whatever they're doing, make it clear that your organization will inflict those negative consequences.

There are more subtle ways to threaten the DOE with legal action than to say "if you proceed with this program, we will be forced to pursue legal action." State what exactly is not legal about what they are proposing--they'll fill in the rather obvious blank if you identify yourself as a member of an organization explicitly formed to oppose the proposal. Likewise with publicity campaigns. This is only credible, however, if a large number of people from that organization write in and identify themselves as such, and it really works when that organization has an ongoing publicity campaign that has reached the decision-makers.
This is also different from the standard protest letter or letter to the editor in that the decision-makers actually receive the letter or a summary and are obligated to at least publish it. As such, speak as a negotiator and use negotiating tactics; this is not a place to do general-public-type PR.
Likewise, don't use personal attacks and don't try to tell them about what they've done. They know what they've done and using personal attacks lessens the probability that they'll accept a face-saving compromise. I'm not advocating for the further wussification of society, just differentiating between the approach needed for PR and the approach needed for negotiation. It is in fact fatal to weasel out, or to suggest solutions that don't involve the agency you're complaining about (like legislation).

Oh, and don't make grammatical and spelling errors, or do anything else that undermines your credibility. Do not feed the 'allegators'.