ACTION NEEDED - 100% Tariffs

my comment was very similar to davids. these proposed tariffs hurt all the wrong parties and additionally hurt any kind of progress towards a solution to the underlying dispute.

Thanks David. I paraphrased your comment.

It appears there’s a process before comments are posted. Does anyone have any experience with how often new comments are posted? I’d be interested in checking out the updates.

And thanks, Neal, wanted to throw a domestic production standpoint in there. As someone who manages business in the three tier system, I think this is going to be a disaster if it continues to escalate.

Sorry, duplication

Sorry, duplicated my post.

They get reviewed to make sure there is no inappropriate content. Likely not going to get looked at over the weekend.

Matt - there is a process. Not all agencies are required to accept comments, but if they do, they are supposed to acknowledge the comments when they issue their final rule.

I’ve been involved with a few regulatory and even statutory changes at the federal and local levels. Sometimes the agencies will simply go through the motions and then they’ll just do what they want. But they have to address reasoned and relevant arguments. There are some ways to ensure that at least your comments get noticed, so I would suggest the following format, which they will be familiar with.

  1. At the very beginning of your comment, be sure to clearly identify exactly what you are commenting on by the docket number, subject heading, federal register date, and page number. Some of this will be automatic if you use the website, but be sure.

  2. State why you are interested in that specific issue and note any experience, expertise, or credentials you have in the field. Some guy with an opinion is less effective than someone who can connect his business or profession to the issue.

  3. Identify the specific issues you object to and why, and make your alternative recommendations. It’s helpful to identify the paragraph and page number and even to cite the language you would change if you can do that.

  4. Analyze the issue and let them know how it will affect the particular industry you are in.

  5. Provide any citations or authorities that you used in your analysis, if any.

  6. Don’t just say that you support or oppose something. Those comments will be largely ignored. Explain how the proposed action would affect your specific individual situation. The key here is that there may be unintended consequences that have not been considered and if you raise those, your comments will be far more effective. Matt identifies some of them - the impact on jobs in the US, the impact on the distribution system, etc. Those are exactly the types of things that are supposed to get attention, if anything will.

  7. Keep on point and don’t include irrelevant information.

  8. Don’t mention politics or parties or personalities. Be like the Godfather, i.e. nothing personal, just business.

When finally issuing the rule, they usually group similar comments rather than address each individually, but the decision won’t be made simply on polling popularity.

BTW - You can also request that they provide additional time for further study and comments.

Greg,

You have to already be in the comment area for the specific case, so putting the docket number in the comment is no longer required.

Yeah. I figured.

Back in the early 90s we wrote letters.

What is this “wrote letters” you speak about? [wow.gif]