The National Park Service is following the requirements of the National Environmental Protection Act known as NEPA. There are several steps in the process that individually must be put before the public for comment. This step is reviewing and commenting on the DRAFT Management Plan and Environmental Impact Statement. After reviewing all the comments from the public and government, the NPS will issue a final plan. You cannot challenge a final EIS if you have not commented on the draft EIS. This gives you what is legally known as "standing". It is not pointless to summit comments, it is a legal necessity if you want to remain in the process. Most of the time it is organizations - advocacy groups, etc., that play a role in the whole process, but, from my experience, the agencies really appreciate comments from individuals familiar with the issues and who are not just parroting form letter
No argument there. Submitting a form comment letter is pointless. 10,000 form letter type comments basically counts as one. Being a very active advocate for the PCTA for over 15 years I'm familiar with the process.