> From: Kent Crispin <kent@songbird.com>
> In your opinion, is the paper vs email/fax situation similar as far as
> comments sent to NTIA?
I just talked to a committee staffer, and his comments are:
- fax to Commerce is pretty useless, unless it is an "expected"
document. The staff looking through the faxes often mislay the ones
that they were not looking for, and the piles are not well-sorted and
routed.
- since there is a specific email comment address, and it is automated,
that would be a reasonable avenue, but email is still "discounted"
compared to letters. You might send individual comments to the
email, and mention that there will be a followup letter.
- letters are still the best. There is an entire staff dedicated to
sorting and routing them. They get even more attention when signed
by more than one person. Hard to do in email....
> That is, will Magaziner and company pay more
> attention to typed letters than to email? [Personally I believe that
> they will pay little attention to comments at all, unless they are
> overwhelmed.]
>
I expect they will pay little attention even when overwhelmed.
> In your opinion, for NTIA comments, would it be counter-productive to
> send copies of comments to both to the email address, and physically?
>
That sounds good to me.
> Do you think it would be wise to delay submission of NTIA comments to
> the last possible moment, but send letters to congress early?
>
I don't think NTIA comments will help much at any time, but I would _not_
delay submission. Take enough time to be detailed, and refute specific
issues in the Rule, but send a steady stream.
Meanwhile, get to Congress as early as possible. That is where the
action is right now, if you want to see review in a few months.
Remember, all appropriations start in the House. They cannot do this if
the House restricts the appropriation.
> This gets to a larger issue -- is delaying the GP a good general
> strategy, in that it will give us time to gather support?
>
Oh, yes! That was the first tack, the previous few weeks. It was not
successful, in that the GP made it into the Fed Reg, but at least that
took a few more weeks. Remember, last summer the thing was announced
July 1, and published July 2.
Sometimes, just getting Congress to make some noise about a possible
hearing is enough to delay a Rule.
Now, we want the proposed Rule not to be made final.
And if it is made final, we will need to go to the courts to enjoin its
implementation.
And in the meantime, we need to get the registry operational!
> OTOH, it may be the case that this will drag on for months, and in that
> case, the sooner that senators get involved, the better, don't you
> think? And, given a letter to a congressperson, a letter to a
> senator should be a simple edit.
>
True. Good idea.
But with the Senate, you have to think in years, not months. Unless we
can cast this as another Magaziner health-care-style boondoggle, and
severely politicise it.
I don't think this group is capable. Heck, where was the counter press
release?
WSimpson@UMich.edu
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This archive was generated by hypermail 2b29 : Sun Jan 30 2000 - 03:22:25 PST