Monday, March 1, 2021

Reader Comment – Commenting on Regulations

This afternoon Laurie Thomas, a long time reader and the person I turn to for up-to-date MTSA and TWIC information, left a comment on my Saturday post about comments submitted on the CFATS advanced notice of proposed rulemaking. Her comments on the practice of letter writing campaigns reflect my thoughts on the matter (making us both geniuses – grin).

She did point me towards an article in the Spring 2013 issue of the Coast Guard Proceedings on “Effective Commenting” (pgs 47-9). This article (admittedly slanted towards CG regulatory actions) provides a very good discussion about how comments are used in the regulatory process. For the most part, the CG actions on comments outlined in the article are required by regulation for all federal government agencies.

While looking for the article mentioned in Laurie’s comment, I found an interesting issue of the Coast Guard Proceedings (Spring 2010) that has multiple articles on the regulatory development process. Again, there is a CG slant, but there is plenty of good information about how the regulatory development process works. They would be excellent reading for anyone looking for more information about the process.

Over the years I have commented on a large number of rulemakings for a wide range of agencies. I think it has only been once or twice that I had an actual influence on how the resulting regulation turned out. But even if no agency ever agreed with my suggestions, I would continue to submit such comments. No one will ever listen to my suggestions if I never make them.

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