Here is the Federal government’s official guideline for submitting comments regarding notices of proposed rulemaking:
Some organizations have encouraged their members to submit “Form letters” and barely modified “Templates” as a submission. As noted on this blog last month, this is the wrong way to go about making a difference in the rule making proceeding.
Here is the official statement from the U.S. government on the Regulations.gov web site:
Organizations often encourage their members to submit form letters designed to address issues common to their membership. Organizations including industry associations, labor unions, and conservation groups sometimes use form letters to voice their opposition or support of a proposed rulemaking. Many in the public mistakenly believe that their submitted form letter constitutes a “vote” regarding the issues concerning them. Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound reasoning and scientific evidence rather than a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.
Of course as showed previously, many comments were filed by those that followed some organizations’ misdirection to file form letters.
When I checked this morning, I found this in the comment file including the first one labeled “Template”.
From the linked PDF above:
8. The comment process is not a vote. The government is attempting to formulate the best policy, so when crafting a comment it is important that you adequately explain the reasoning behind your position.
9. Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, fisherman, businessman, etc.) say so.
10. Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well you are more likely to influence the agency decision making.
If you still wish to file a form letter and submit a template letter with “Template” as the first word of your comment, go right ahead and waste your time.