Comments on "Rulemaking vs. Democracy: Judging and Nudging Public Participation That Counts"

August 2014
Citation:
44
ELR 10681
Issue
8
Author
Michael Halpern

Farina et al. mostly concentrate on the value of mass comments to the agency rule writer, and seem resigned to the fact that mass comments will continue. They suggest an intriguing, multitiered system called Regulation Room that can help rule writers distinguish between comments that express preferences and comments that provide expertise. But that isn’t the whole story. In this response, I argue that public participation should both facilitate meaningful input into a rule and help shape public dialogue around the rule.

Michael Halpern is the Program Manager for Strategy and Innovation, Center for Science and Democracy, Union of Concerned Scientists.

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