How the Crowd Could Help Keep Zinke Accountable

The Wilderness Society is asking volunteers to ensure that the Americans who shared their opinion on National Monuments are heard by the Trump administration.


Secretary of the Interior Ryan Zinke says he wants to be neighborly.

In late April, President Trump ordered the Department of the Interior to review the National Monuments created or enlarged by the Antiquities Act—27 National Monuments in all—with an eye to shrinking or even eliminating some of them. Shortly after, the Department announced that they would give Americans the opportunity to voice their opinion during a public comment period. In the press release Secretary Zinke said he wanted to be a “good neighbor” by “listening to the American people who we represent.”

More than 1.4 million comments poured in between May 11 and July 10, and now that the comment period is over, The Wilderness Society wants to ensure that Secretary Zinke follows through on his promise. The organization has asked their supporters to participate in a crowdsourced audit of the comments to see where Americans’ sentiments lie. The audit will also use machine learning to assess the remainder of the 1.4 million comments that volunteers can’t get to themselves.

The crowdsourced audit is being led by a small firm called Key-Log Economics, which specializes in research and strategy for land and resource management. In 2016, Key-Log carried out a similar review of the comments submitted to the Federal Energy Regulatory Commission as part of the scoping process for a proposed pipeline in the eastern United States. Altogether, 83 volunteers helped analyze 2,870 different comments, of which 1,631 were unique; the remainder were form letters or petitions.

The audit for The Wilderness Society makes that review look like child’s play. Key-Log has pulled 30,000 comments at random from the nearly 1.5 million submitted. Spencer Phillips, the founder of Key-Log Economics—and a former senior director at The Wilderness Society—tells Civicist that they went through several surveys to ensure a statistically accurate sample size.

Phillips’ goal is to have volunteers get through as many of those 30,000 as possible in just three weeks. A subcontractor is providing a machine learning tool to help parse the remaining 1.4 million comments. (The crowd will also act as a check on the AI; people will read a sample of the comments reviewed by machine and Philips and his colleagues will check to make sure that the results are in sync.)

A public comment I reviewed as part of the survey.

“What we want to do, by looking at every comment, is kind of make an airtight case…that this is in fact the sentiment of the million or so people who took time out to say something about this issue,” Phillips told Civicist. The all-encompassing scope of the review makes it harder for critics or the administration to accuse The Wilderness Society of cherry-picking the data.

When we spoke last week, Phillips said that they had between 100 and 200 volunteers already signed up. (An exact number was hard to fix because of test accounts and possible duplication as a result of technical difficulties.) Less than 24 hours after The Wilderness Society shared the opportunity across their social media accounts, the system crashed and Phillips had to upgrade his Google account to accommodate more volunteers. Within a day, volunteers who might have encountered difficulties were alerted that the review was back online.

The process is simple: You indicate interest by filling out a form and Key-Log emails instructions with a copy of a comment at the bottom of the email. You click through to a form assigned to that particular comment and go through a checklist, noting any names or identifying information given, like hometown or state; checking off the topics raised, like hunting, natural beauty, outdoor recreation, or historical significance; noting any of the National Monuments mentioned by name; and indicating on a scale of one to 10 the author’s opinion on shrinking or eliminating national monuments, from strongly against to strong for. Once you click submit, you have the option to review another comment right then, or to come back later.

One of the questions on the survey.

Phillips told Civicist that he is unaware of other organizations using crowdsourcing to parse public comments. He likens it to citizen science projects that put the crowd to use identifying galaxies or tracking different animal species. He added that he would like to see a more technologically-savvy individual or organization create open source software that would make projects like his easier to spin up and apply to other issue areas in which the public is polled, like transportation or energy.

The goal of the audit is twofold. The first aim is, obviously, to try to hold Secretary Zinke and the Trump administration accountable to their promise to listen to Americans on this issue. This could prove challenging, because although Secretary Zinke claimed that there were no predetermined outcomes for any of the monuments, the announcement of the review was made with the assumption that Americans are against the expansion of federally-protected lands through the Antiquities Act. “For years, the people of Utah and other rural communities have voiced concern and opposition to some monument designations,” Secretary Zinke said in a press release titled “Finally, rural America has a voice again.”

“But too often in recent history, exiting presidents make designations despite those concerns,” he added. “And the acreage is increasing.”

Zinke has already recommended that Bears Ears National Monument be reduced in size. (The comment period for Bears Ears was shorter than the others, ending on May 26.) Zinke has also announced that several National Monuments, including the Grand Canyon-Parashant National Monument and the Canyons of the Ancients, are no longer under review and that they will not be seeking modifications.

Dan Hartinger, the deputy director of Parks & Public Lands Defense at The Wilderness Society, points out that Secretary Zinke’s boast that the public comment period is a first is disingenuous. In advance of the designation of Bears Ears as a National Monument, for example, Sally Jewell, Zinke’s predecessor at the Department of the Interior, held a full-to-bursting three-hour public meeting at a Utah community center.

If the audit shows overwhelming support for National Monuments, The Wilderness Society hopes that the information in their report will give the Trump administration pause before shrinking or eliminating any monuments. If that fails, they will use it to show the public that the administration is not following through on their promises. Legal action is also possible, although the path forward is not necessarily clear; in the case of the Atlantic Coast Pipeline, for example, the federal government has an obligation to address the concerns raised by citizens during the scoping phase, and if they demonstrably fail to do that an individual or organization can take them to court and impede the development of the pipeline. The government’s obligation to listen to the public when it comes to revoking National Monuments is less evident.

The second goal of the audit is to engage the supporters of The Wilderness Society in an action. The participatory nature of the process gives supporters ownership in the project beyond their annual donations. They get to do something.

“We hope to provide our members and supporters and all those who care about public land across the country a way to engage personally in defending and engaging in the democratic process on public lands,” Hartinger said. “Ultimately as citizens we are the part owners of these lands so having people feel a part of the process and have a tangible connection to this review and any results that come out of it is important going forward.”

Hartinger added: “We don’t anticipate that these types of proposed changes or frankly attacks on public lands are going to stop any time soon, so having the public engaged on these issues is important going forward.”