4. If a rule raises many issues, do not feel obligated to comment on every one – select those issues that concern and affect you the most and/or you understand the best.
5. Agencies often ask specific questions or raise issues in rulemaking proposals on subjects where they are actively looking for more information. While the agency will still accept comments on any part of the proposed regulation, please keep these questions and issues in mind while formulating your comment.
6. Although agencies receive and appreciate all comments, constructive comments (either positive or negative) are the most likely to have an influence.
7. If you disagree with a proposed action, suggest an alternative (including no alternative at all) and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective.
8. Te comment process is not a vote. Comments are designed to help 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.) then 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.
11. Consider including examples of how the proposed rule would impact you negatively or positively.
12. Comments on the economic effects of rules that include quantitative and qualitative data are especially helpful.
13. Include the pros and cons and trade-offs of your position and explain them. Your position could consider other points of view, and respond to them with facts and sound reasoning.
14. If you are uploading more than one attachment to the comment web form, it is recommended that you use the following file titles:
o Attachment1_<insert title of document> TPI Turf News November/December 2023
o Attachment2_<insert title of document> o Attachment3_<insert title of document>
Tis standardized file naming convention will help agency reviewers distinguish your submitted attachments and aid in the comment review process.
15. Keep a copy of your comment in a separate file – this practice helps ensure that you will not lose your comment if you have a problem submitting it using the
Regulations.gov web form.
Posted Comments After submission, your comment will be processed by the agency and posted to
Regulations.gov. At times, an agency may choose not to post a submitted comment. Reasons for not posting the comment can include:
• Te comment is part of a mass submission campaign or is a duplicate.
• Te comment is incomplete. • Te comment is not related to the regulation. • Te comment has been identified as spam. • Te comment contains Personally Identifiable Information (PII) data.
• Te comment contains profanity or other inappropriate language.
• Te submitter requested the comment not be posted.
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.
For more information about the sod checkoff, to see webinars, and to stay up to date on the latest details, please visit
www.SodCheckoff.org.
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