Make these points, in your own words

• The 'What's New' section reveals that BLM published a proposed rule in the Federal Register on the same day, September 4, 2026, that it released only draft Chapters 1 and 2 of an incomplete EIS.Read the point +

  The 'Project Description' states that 'The analysis in the EIS will inform and support a rulemaking,' yet the rule was already proposed before the analysis existed. Publishing a final regulatory proposal before completing the required environmental review inverts the NEPA process and signals a foregone conclusion. BLM should withdraw the Proposed Rule and reissue it only after the Final EIS is complete and the mandatory post-filing review period has elapsed.

• The 'Project Description' provides no independent agency determination that existing 43 CFR 3160 requirements are inadequate.Read the point +

  It states only that this entire effort 'is in response to a May 12, 2026, petition for rulemaking from the Alaska Oil and Gas Association (AOGA),' making the regulated industry's demand the sole stated basis for action. An EIS that exists to implement an industry petition without any independent agency finding of regulatory need lacks the reasoned basis NEPA and the APA require. BLM should publish a separate statement of need based on its own review of current permitting requirements before the comment period closes.

• The 'Project Description' defines the entire scope of this EIS as the effects of 'qualifying production sites' but never defines what makes a site qualifying, states no site-count range, no acreage threshold, and no geographic limits within the NPR-A.Read the point +

  Without that definition neither the public nor a reviewing court can determine whether the EIS covers the right universe of actions or whether cumulative impacts have been scoped correctly. BLM should define 'qualifying production sites' with specific eligibility criteria, a range of sites that could qualify, and a geographic scope statement before the public comment period closes.

• The heading 'How to Submit Comments on Chapters 1 & 2 of the EIS (Due by November 9, 2026)' instructs the public to address 'potential environmental concerns the BLM should consider' while only purpose, need, and alternatives chapters have been released.Read the point +

  The resource impact chapters covering air, water, wildlife, and subsistence have not been published. Asking commenters to identify environmental concerns before those chapters exist makes the comment period a formality rather than a meaningful opportunity to respond to actual analysis. BLM should release the full draft EIS and reset the comment period clock from that release date.

• The 'What's New' section states that 'The BLM will accept comments on both, but comments will be collected separately' for the EIS and the Proposed Rule.Read the point +

  Routing environmental comments and regulatory comments to separate systems means the agency has no formal mechanism to reconcile its environmental findings with its regulatory choices in a single record and no obligation to explain how one constrains the other. BLM should explain in writing how it will integrate both comment streams into one administrative record and how EIS findings will constrain the final rule.

Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.