May 24, 2010

ACTION ALERT: AWA Supplement Guidelines - Comments Can Now Be Submitted

UPDATES: None so far.
5-24-2010 National:

First, and most important is, Thanks to all those who sent in something to Regulations.gov to explain what was wrong on their website, without that help comments could not be submitted. (Note: No matter what Regulations.gov may say about what folks submitted, it got them to make changes. Hats off to folks)

OK, there are a few things folks need to know, I have copied their "comment screen" (See below) so folks can know BEFOREHAND what you will see when you get there. The reason I have done this is, they LIMIT the amount of time you are allowed to make comments (20 minutes per time you are on their site) (Yes you can go back and make another comment). I strongly suggest folks study the screen before making comments (Click on screen to see it full size).

My comments on Keeping your name ANONYMOUS/PRIVATE (even though their screen says they will be viewable) will continue after the following screen:


First we need to look at what the Federal Register says:
SUPPLEMENTARY INFORMATION:
Posting of Public Comments

Please note that all comments received are considered part of the public record and made available for public inspection online at http://www.regulations.gov. Such information includes personal identifying information (such as your name, address, etc.) voluntarily submitted by the commenter.

If you want to submit personal identifying information (such as your name, address, etc.) as part of your comment, but do not want it to be posted online, you must include the phrase ‘‘PERSONAL IDENTIFYING INFORMATION’’ in the first paragraph of your comment. You also must locate all the personal identifying information you do not want posted online in the first paragraph of your comment and identify what information you want redacted.

If you want to submit confidential business information as part of your comment but do not want it to be posted online, you must include the phrase ‘‘CONFIDENTIAL BUSINESS INFORMATION’’ in the first paragraph of your comment. You also must prominently identify confidential business information to be redacted within the comment. If a comment has so much confidential business information that it cannot be effectively redacted, all or part of that comment may not be posted on http://www.regulations.gov.

Personal identifying information and confidential business information identified and located as set forth above will be placed in the agency’s public docket file, but not posted online. If you wish to inspect the agency’s public docket file in person by appointment, please see the FOR FURTHER INFORMATION CONTACT paragraph. ....

ANONYMOUS / PRIVATE Name:
Notice how confusing "Privacy of Personal Information" is, in their "Privacy and Use Notice" they mention anonymous comments, but they refer you to the Federal Register for an answer. Well, there is nothing mentioned, so whether you can or cannot keep name etc. anonymous, I'm not sure, but read on.

However, they do say, "to keep name etc. confidential" place it in the comments area -first paragraph-. That may mean folks can leave the boxes on the left completely blank, again, I'm not sure, but read on.

Note: Look closely at the screen above, they note "* Required Fields" and the ONLY required field is "Comments" which means the boxes on the left (the first three indicate "viewable on regulations.gov site") can be left blank. So it looks like it is your choice whether to enter your name, in the boxes on the left -OR- whether to enter your name etc. in the comments area -OR- not enter it at all; anonymous (Only question I have, is, if anonymous will they even consider what it says?).
However, do not forget, placing confidential information (name etc.) in the comments area will further limit your overall comments, maximum allowed is 2,000 characters and that includes spaces.

PREPARING COMMENTS BEFOREHAND:
Because of the 2,000 character limit and the 20 minutes on-site limit, I strongly suggest folks prepare comments off-line and check the character count. If you use WORD it has that ability.

Again, because of limits, it will be essential that folks say things in as few a words as possible. Difficult, yes, but not impossible. For me, those limits are a real problem, I'll have to rewrite several times to cut my wordiness.

Once you have your off-line comments ready, then get on-line and simply copy your comments into the Regulations.gov web form -comments area-.
Note: Since they do not provide a way to print your comment, you may wish to do so off-line before entering your comment. Also remember, once they post it, you can do a print screen of what is posted. Options...

MULTIPLE COMMENTS:
Yes, you can enter as many as you want, just sign off Regulations.gov and then go back on and enter another one. You may also do this over several days.

And, this may be a way to get around the 2,000 character limit. ex: Suppose you have 6 gripes / suggestions about some particular thing. Do this, put 3 in one comment and 3 in another, even do it over a few days as you think of things.

MANDATORY: OAG Docket No. 134:
This must be the first thing in your comments area, this is mandatory, without this your comment will be ignored.

WHERE TO POST COMMENTS:
OK, now you have your comments ready, here is where you go:
http://www.regulations.gov/search/Regs/home.html#docketDetail?R=OJP-2010-0001 Look on the lower left where it says "Comment Due 7-13-10 11:59 PM" just click on that and enter what you have prepared beforehand.


If anyone has a problem I would appreciate knowing about it, and a resolve if possible, this way I'll update this post to let other folks know about it. Finally, folks may want to check back -from time to time- to see if there have been updates to this page.

Have a great day & a better tomorrow.
eAdvocate

PS: See my other commentaries (top of page) as to things folks have found which will affect RSOs if these Supplemental Guidelines are passed into law.

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