Believe it or not, every comment that is submitted by the
public in response to a Federal rule is read by members of a rulemaking team,
be they Regulatory Development Managers (RDMs), subject matter experts (SMEs),
technical writers (TWs), or others who are involved in the creation of the
rule. Typically, each comment is
reviewed, summarized, and logged using a public comment matrix. That said, depending
on the content, not all submitted comments warrant a summary. Only those containing clearly communicated,
constructive content that supports the commenter’s points tend to make the cut.
Therefore, if you are passionate or have concerns about a Federal rule and want
to make your voice heard in the rulemaking process, remember to SING:
Straightforward
Impassive
Noteworthy
Germane
Straightforward
The first quality is, well, pretty straightforward (see what
I did there?). Straightforward communication is effective communication. Your comment should be simple, concise, and
easy to understand. It should clearly identify whether you are opposed or in
favor of a particular regulatory action, contain a logical and supported
explanation behind your reasoning, and, when possible, provide a citation for
each specific section of the rule to which your comment applies.
Impassive
When you take an impassive approach to comment submission,
you free the comment from emotion. This
allows the comment to be constructive rather than destructive, and to utilize
reason and logic to have the highest impact on policymakers. If you disagree
with a regulatory action, validate your position with a logical explanation,
analysis, or alternative. Refrain from name calling, no matter how strongly you
feel.
Noteworthy
A well-supported comment is a noteworthy comment. It
contains information that is interesting, significant, and worth paying
attention to. When an agency reviews the comments they receive, they look for
sound logic and scientific reasoning. The more data, facts, and expert opinions
you include in your comment to support your position, the better. Attachments
with charts, tables, and figures are great ways to enhance your comment;
however, limit their use to those that best support your position. Other noteworthy
information to include are a list of pros and cons or trade-offs, and statements
that describe how and why you believe you will be directly impacted by the
regulation in question.
Germane
Comments should be relevant to the subject under
consideration, and contain pertinent, applicable information relating to your
position. For example, you should not submit a 75-page PDF attachment concerning
the repopulation of sturgeon on the Hudson River if your opposition to the rule
is about oil pollution. Additionally, do not drone on about how your
great-great-great-grandfather’s second cousin’s brother (twice removed) was a Charter
Boat Captain when you have professional industry connections that are germane
to the rule.
These tips are the only notes you need to keep in mind when
you develop comments. The example below shows the difference between a non-effective comment and an effective comment.
Non-effective comment:
Effective comment:
Use your voice effectively in the rulemaking process: comments that SING are more likely to have an impact on regulatory decision-making. For more information on submitting effective comments, go here!
