Activists Generate Lots of Duplicate Form Letters on Crude-by-Rail, but Few Substantive Ones

After the U.S. Department of Transportation’s (DOT) released proposed new regulations this summer on crude-by-rail transport, a number of environmental groups who oppose shale development – and indeed, any form of transportation involving oil and gas resources – proclaimed loudly that the public was outraged; that everyone believed the regulations didn’t go far enough; and that hundreds of thousands had submitted comments saying so. According to Earthjustice:

“Today, citizen groups submitted more than 145,000 individual public comments to the Obama administration on two rulemakings on the safety of oil trains and emergency response … The strong public response was highly critical of the draft regulations proposed by the Department of Transportation.”

That sounds like quite a public outcry – until you actually read the individual submissions, which are available through the Federal Register. Late last week, EID began the process of sorting through all those comments individually – a task that would have been admittedly pretty difficult if there were in fact 145,000 comments to actually get through.

Thankfully, far from the hundreds of thousands of comments touted by the activist groups, DOT ended up registering a grand total of only 3,306 comments. And here’s the best part: nearly 60 percent of those submissions were form letters, with only a small fraction of those constituting unique submissions by genuinely concerned (and/or real) citizens.

Of the comments that were unique submissions, the vast majority did not exceed a single sentence in length.  Here are a few examples:

“We need to protect our environment; in turn, we are protecting ourselves.” [Link]

“It is vital to ensure the continued usage and protection of these lands in order that [sic.] generations we know not will be able to have them to further the wisdom of life.” [Link]

“Make it safe, we need our water!” [Link]

Boil it all down, and the number of actual, genuine, non-form letters submitted in opposition to crude-by-rail transport barely exceeded 350 – or roughly 0.21 percent of what the activists claim as their number. And while a few local businesses in support of crude-by-rail transport also submitted what amounted to short form letters to the Federal Register, those constituted 7.3 percent of all form submissions, with activist groups making up the remaining 92.7 percent.

When Earthjustice recently filed suit with the Sierra Club and others in Sacramento, Calif., forcing the company being targeted from halting its crude transloading operations, Earthjustice attorney Suma  Peesapti declared that “this is the first crude transport project that has been stopped dead in its tracks in California.”

Of course, that’s the real goal these activists are trying to achieve across the country. It’s not about making crude-by-rail transport safer – despite what the comments may say. It’s about blocking this mode of transportation entirely, with an eye on blocking the actual resource from being produced in the first place.

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