Tuesday, 11 July 2017

CCPIA Public Comments ('Tips of Submitting Effective Comments')

The US government is obviously fed up with time-wasting commenters on the www.regulations.gov website and has produced these Tips of Submitting Effective Comments'
. The summary could be addressed to the time-waster vacant comments of the coineys:
Read and understand the regulatory document you are commenting on
Feel free to reach out to the agency with questions
[...] The comment process is not a vote – one well supported comment is often more influential than a thousand form letters
So coineys just cutting and pasting the ready-made answers such as provided by lobbyists like Peter Tompa or Blondie Sue McGovern which do not address the actual contents of the regulatory document, but merely some imagined paper tiger argument are no way to present an effective comment. Of course.
7. If you disagree with a proposed action, suggest an alternative (including not regulating at all) and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective.
Suggesting a recording scheme mirroring the UK's PAS is obviously not a way to address any issue regulated by the 1970 UNESCO Convention or the US legislation implementing it. This is simply a case of the commentator not reading the document being discussed and having no idea about what this 'alternative' actually does and why.
8. The comment process is not a vote.
Peter Tompa and his followers simply cannot get their heads around this seven-word concept. Duh. Here is the same idea again (too many words for coineys?):
Form Letters
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.
But I'd say the best tip of all for collectors of dugup antiquities is not there. "Think for yourselves, don't listen to Peter Tompa".

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