Friday, December 1, 2017

Don’t overlook public comment periods

Last week’s column about the Cuomo Administration’s proposed regulations for employee scheduling closed out by encouraging the reader to reach out to the Department of Labor while the public comment period is underway. 

Most folks would look at that suggestion dismissively, fully believing that their opinion means nothing. 

Don’t ever think that way.

Public comment works. I’ve seen it firsthand.

Back in 2011, this column looked at a proposal by the Obama Administration which would have excluded all minors (except the children of the farm’s owners) from most farm work and all animal husbandry, which would have killed the future of agriculture in this country and destroyed the 4-H and FFA. Thanks to the wonders of in the internet, the column went viral almost overnight and farmers, high school students, ag colleges, talk radio hosts, and politicians heartily voiced their opinions in the closing days of the public comment period. After that column made its rounds, public input increased tenfold to the US Department of Labor in a matter of just a few days. We beat back the regulations and it was a huge win for farming….all because people made their voices heard. 

It’s wonderful that our government gives us the chance to do that -- most don’t. Luckily we had founding fathers like Ben Franklin and Thomas Jefferson who were adamant about citizen-driven discussions, something that caught on in New England town halls and similar movements that followed and continue to this day.   

The process in a nutshell: When an executive branch, be it at the state or federal level, is looking at creating policy or has proposed a change in policy it opens up the public comment period during which a special committee or the agency charged with enforcement of the new policies accepts either oral opinions (at special meetings) or written comment (via email, websites, or postal mail) regarding the proposals. After the period closes, that group goes back to the drawing board and either alters or, as was the case with the farm rules, scraps it entirely.

When delivering your comment there are five basic rules you should follow.

Be educated. Take the time to download the new rules and read through them. Also, read up on why they were created. Don’t take the word of radio/TV talking heads, your favorite elected official or columnists like me. Sure, we can lead you to an awareness or an understanding of government action, but you need to take ownership of your knowledge of the issues.

Be educational. Most policymakers have likely not been in the line of work, science, or art that they might be looking to change. But you have. Explain how the new rules will affect any number of things -- your workplace, your family, your community, the environment and the economy. Your real world perspective, from being in the trenches, is what the writers want to hear. Only you, being in the shadow of the dominos, can give the most realistic story of what could happen.  

Be professional. Although a proposed regulation might get your goat, maintain a poker face. Anger and resentment never win over people you are trying to influence. You have to be able to sell policymakers on your ideas – so be a good salesman…be respectful and positive, never demeaning.

Be to the point. Some public comment periods can be overwhelming to governmental agencies. With the aforementioned farm rules, the US DOL received 13,000 written comments. That’s 13,000 letters and emails they have to sift through and read individually. Don’t put them to sleep. Keep it short, just a few paragraphs or nothing longer than a newspaper column. 

Be yourself. Far too often, organizations you belong to will tell you to send a letter that they’ve written to an elected official or a department. Never, ever do that. If the individuals overseeing the task see a few hundred of the same letter it ends up making said letter meaningless, even when received in volume. It’s like activist spam. They want fresh ideas. Fresh voices. Fresh perspectives. They want you.  

It sounds like it could be a daunting task, but it’s not. The daunting task come when you have to live with a series of laws and regulations you didn’t want in the first place. So, do everything you can to stop them from happening. We’re granted a special power as a part of this republic. Use that power.

From the 04 December 2017 Greater Niagara Newspapers  

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