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How to Make Your Public Comment Count

Emily Unglesbee
By  Emily Unglesbee , DTN Staff Reporter
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Federal agencies have to sort through tens of thousands of public comments on their regulations -- is yours going to stand out? (File photo courtesy of Dvortygirl)

ROCKVILLE, Md. (DTN) -- If EPA commenters were baseball players, their batting average would embarrass even the lowliest benchwarmer.

Of the more than 40,000 public comments submitted to an EPA document on soybean seed treatments, the agency identified only 150 comments worth reading. Or, as the agency put it, "approximately 150 comments...contained substantive information and/or cited additional data that was directly relevant."

Not only is that a lousy batting average (.004 for those keeping count) but, more importantly, it represents thousands of missed opportunities for American farmers.

Public comment periods give growers a rare chance to influence regulatory decisions that directly affect their farming operations. To their credit, many take advantage of that, but with thousands of comments streaming into an agency's website, it's easy to be overlooked or dismissed.

Here's how to comment meaningfully and make your opinion count:

RIGHT TIME, RIGHT PLACE

Regulations.gov can be a confusing place. Make sure you are commenting on the right docket for the right rule, regulation or chemical review. Keep an eye out for the blue "Comment Now" button.

The comment box allows you to upload additional documents, and gives you a 5,000-character limit. That's just 17 tweets, for the millennials out there. Choose your words carefully, which means...

FORGET FORM LETTERS

Check the public comment section of any recent pesticide decision and you'll find thousands of identical, pre-prepared statements copied and pasted over and over, with a different name signed to each one. These form letter campaigns have become a popular way for companies and organizations to flood a federal agency with their point of view, but they're unlikely to sway regulators.

"The comment process is not a vote -- one well-supported comment is often more informative to the agency than a thousand form letters," the EPA notes in its "Tips for Effective Comments."

In the soybean seed treatment document referenced above, the EPA notably excluded what it called "letter-writing campaigns" from the "150 substantive comments" it analyzed.

Iain Kelly, director of regulatory policy and issue management for Bayer, said it's more important for EPA to hear growers' personal, field-level experiences, but please...

JUST THE FACTS, MA'AM (OR SIR)

In its analysis of soybean seed treatments, the EPA also dismissed "anecdotal claims of yield benefits or lack thereof."

Try to stick to verifiable information, such as the results of any on-farm strip tests or farm record details on pesticide usage. Consider including or attaching expert opinions that back up your personal experience, when possible.

DETAILS MATTER

Give the agency a reason to listen to you, by carefully identifying yourself, your occupation and how the regulation in question will affect you.

For example, Bayer's Kelly recommends including these details in a comment on a pesticide regulation: your farm location, acreage, crop rotation, pest history, specific pesticide use (seed treatments, foliar or soil applications), and the benefit you see from them.

THINK AHEAD

If the regulation in question would alter how you farm, tell the agency exactly what would change, Kelly added.

In the case of a pesticide regulation, for example, name the alternative chemicals you would use, how often you would use them and in what quantity and form.

See EPA's "Tips for Effective Comments" here: http://bit.ly/… and the rules for public comment sections here: http://bit.ly/….

Emily Unglesbee can be reached at Emily.unglesbee@dtn.com

Follow her on Twitter @Emily_Unglesbee

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Emily Unglesbee