General Tips for Writing Comments
Tips for Submitting Comments Online
To encourage greater public participation in the regulatory process, federal agencies are increasingly turning to the Internet. The federal government’s e-rulemaking website, Regulations.gov and collaborative efforts like Cornell University’s moderated Regulation Room website (regulationroom.org) simplify the process of commenting on proposed rules, making it easier for citizens to have greater voice in agency rulemaking.
The federal government operates Regulations.gov, and almost three hundred federal agencies use it to solicit rulemaking comments. It allows direct input to those agencies, and comments submitted there become part of the agency’s rulemaking record. But Regulations.gov does not allow the public to discuss proposed rules in a discussion-board-style forum. To encourage such discussion, others, including Cornell’s Regulation Room, which has partnered with the Department of Transportation (DOT), work with select federal agencies to solicit public comments online. Unlike Regulations.gov, not every comment submitted to Regulation Room makes it to a federal agency. Website moderators frequently post new questions for the public to consider about a proposed regulation, and Cornell compiles comments on the Regulation Room website for the agency by summarizing common themes and providing examples of the online comments. Regardless whether you submit your comment directly to an agency or use a moderated website, to have the greatest impact, it is important that your comment be a well-thought out expression of your point of view.
Regulations.gov does not generally moderate comments made to proposed rules. But moderators of websites like the Regulation Room facilitate online discussion by outlining different issues related to the proposed rules being discussed. They also monitor comments from users and may pose questions based on individual comments. Once you have submitted a comment online, you may find it useful to check back again and see if your comment has sparked any discussion, additional comments, or questions. By reviewing comments made by others, including the moderator and other users on a moderated website, you may discover other ideas you had not considered. It can also help you to clarify parts of your comment that others have questions about.
If you are interested in a particular regulation or issue and want to submit a comment, be sure to note the date when the comment period will close. You can find this information on the website or in the Federal Register announcement of the proposed regulation. Generally, comment periods are open to the public for thirty to sixty days. This comment period is the same whether you submit a comment online or on paper. You need not submit comments through both the website and the mail; this only duplicates the number of comments the agency must sift through, and it may result in your ideas being lost in the shuffle.
General Tips for Writing Comments
Many of the same principles apply whether you submit a comment online or via mail. You may wish to review The Citizen’s Guide to Influencing Agency Action pamphlet before submitting a comment. Here are some tips to keep in mind, whether you are submitting a comment online or via mail:
· Read the proposed regulation.
· Compare the proposed regulation with the current regulation (if there is one).
· Consider how the proposed regulation would affect you, your business, or your community.
· Formulate your opinion of the regulation.
· Outline the key points you want to make in your comment.
· Find concrete examples of why you think this regulation would be good or bad.
· Draw on your personal experiences to illustrate how the regulation could have a desirable or undesirable effect.
The key to making your comment stand out is to use a logical argument backed by examples of experiences you have had or others in your business or community have had.
Tips for Submitting Comments Online
When submitting a comment online, you should rely on many of the same ideas listed above. There are a few other things you should keep in mind when commenting online:
· Respond to questions posed on a moderated website. These may be general questions about a particular issue or questions directly related to your comment.
· Follow the debate and others’ comments online. This will help you clarify any issues addressed in your comment.
· Review comments submitted by other members of the public. You may find someone with a similar opinion whose comments you would like to support.
The nature of moderated websites like the Regulation Room provides a unique opportunity for people who share the same passion about an issue to engage in an interactive discussion that may help you prepare your own comment.
As in any online community, there is always a danger that discussions will not be civil. As mentioned, federal agencies generally do not moderate submitted comments. But managers of moderated discussion websites like Regulation Room strive to keep inappropriate comments out of the serious debate. Here are some tips to keep in mind when you are submitting comments online to avoid these problems:
· Don’t engage in personal attacks. This will quickly degenerate the conversation, and no one will get his or her true argument across.
· Don’t use wild speculation. While it is appropriate to pose hypothetical scenarios when engaging in debate, it is not appropriate to speculate wildly. If you cannot show a logical reason why A would lead to Z, but you assert that most assuredly A will lead to Z, your entire argument may be dismissed as illogical.
· Don’t go off topic. If you are commenting on the dangers to texting while driving, do not finish you argument with a comment on how expensive you think your wireless phone service is. This will only make you seem unfocused and may make your otherwise logical comments seem less credible.
