First, let's look at why normally these things are not open for public comment. The government could be hampered in its operation by comments and frivolous law suits if they allow public comments on all policies set by various agencies that impact a certain segment of the population (for example the Army only sets policies that impact their service members and possibly their families). Usually policy is determined by the law and it is an internal document to clarify the law for employees or to address specific issues within an agency. An example is that Congress determines that a certain activity shouldn't be paid for with tax payer dollars, such as to pay for inspectors at a horse slaughter plant. The USDA has policy analysts that read the law and determine what exactly that means. As we know, they felt it meant that the plants could pay for their own inspectors. Why they made that determination, I don't know. The intent of Congress was clear during the debate, it was to shutter the nation's horse slaughter plants. However, they argued that other laws conflicted, they REQUIRED an inspector at plants slaughtering for meat that would be exported. I think that was a stretch and that the argument was thin, but if the public had been allowed to comment and our comments had been ignored it would have opened the door to law suits. Unfortunately it was a single policy that impacted a small percentage of the population, so we couldn't ask for them to allow comments at that time.
However, the BLM policy book impacts a number of environmental issues and impacts anyone interested in public lands, including ranchers. So, it should be open to the public. They have acknowledged that by allowing the various Advisory Boards to provide comment. However, this isn't broad enough. That policy handbook should be open to public comments as there are pending changes to a variety of programs (wild horse and burro program, sage grouse, big horn sheep, hunting, grazing...) that impact billions of people. Since the BLM is the most litigated government agency, allowing public comments could even actually lessen the number of law suits. Since it impacts so many they should be allowed to comment if it directly impacts their lives and livelihoods and directly impact the quality of lives of those of us who visit, care about or wish to preserve our national lands and we should be allowed to at least comment on those policies.
Everyone should contact the BLM and the Department of Interior (see below for contact info) and ask that an exemption be made for public comment on the Policy Handbook. Since it is doubtful that they will do the right thing despite public outcry you should also contact your Representative and Senators and ask that they move to allow the public to comment. For this to be effective we are going to need more than a few comments, we are going to need to literally FLOOD them with comments. So, please forward this information to everyone you know and every horse group out there.
BLM Washington Office
1849 C Street NW, Rm. 5665
Washington DC 20240
Department of the Interior
1849 C Street, N.W.
Washington DC 20240
Feedback form: http://www.doi.gov/contact.html