Government Legal, Laws, and Regs

Before you sign that petition

The USDA has been busy approving genetically modified crops for cultivation, including a potato and alfalfa. I’ll have much more to say on GMO later, but I wanted to focus on one aspect of the approval process—the submittal of public comments.

Before the USDA approves a new GMO crop, it opens the approval for public comments. The USDA has to address all of the comments, in one way or another, before the approval. The same holds true for all of the government agencies, and most decisions made by those agencies: the decision goes through a period of public commentary, and the agency has to read each comment and ensure any concerns in the comment are addressed. An example is the recent invitation for the public to comment on the USDA’s proposed changes to the Conservation Stewardship Program.

The GMO potato approval received exactly 308 comments. Considering how controversial genetic modification of food crops is, you might be surprised that there were so few comments, but no there were only 308 comments that the USDA addressed.

Of course, one of the comments was a consolidated document consisting of “identical or nearly identical letters, for a total of 41,475 comments.” What effect did all those 41,475 separate letters have on the USDA decision? They had the effect of one, single, submitted comment.

Frequently when a government decision is opened for public commentary, one site or another will start up a petition for people to add copy and paste comments that the organization will submit to the agency on their behalf. And in every single case, the entire collection of signatures becomes exactly one comment. For the most part, it doesn’t matter how many signatures are attached to the comment, it’s still treated like one comment. It doesn’t matter how many letters are attached if they’re identical, or nearly identical: they’re treated as one comment.

The only time the number of signatures matters, is when there’s enough publicity associated with the signatures to generate interest from the White House or Congress who will then intervene on behalf of the group of people. For the most part, you might as well spend your time knitting socks or tweeting what you had for lunch, for all the impact it will have to submit a comment through a petition.

However, if you submit a comment directly to the agency, it gets counted as one comment. The concerns you thoughtfully detail do have to be addressed. The comment does have an impact. The impact might be small, but it isn’t negligible. Signing your name to a petition is, for the most part, negligible. You’re not doing a damn thing. Not when it comes to federal rulemaking and decisions.

You’re better off focusing on issues that really matter to you and taking the time to write a detailed, thoughtful comment related to those specific issues, than you are blindly signing every petition that comes your way in Facebook, Twitter, or Google+.


Krispy Kreme

Recovered from the Wayback Machine.

I had this most horrible nightmare last night.

I dreamed that I was on a deserted tropical island, and the only thing I had to eat and drink was blueberry bagels slathered in Vegemite, with room temperature, flat Foster’s to wash them down. And it was in color, too. Shudder What does it mean?

I’ve heard enough about Tim Tams to know that I must try them. I live in one of this country’s most sophisticated and urbane cities; only 8% of the population that live here can afford to live here. Surely there must be some shop somewhere that sells a cooky labeled as “sexy mass-market”. That description fits San Francisco so well!

I kept trying to think if there was a particular food item that has similar universal appeal and fondness in this country. One that can also generate the same wistful thoughts, prolonged discussion, and copious drooling from even the most hardened weblogger. Just before I went to bed last night it came to me: Krispy Kreme.

I have seen weblogs devote an entire week to nothing but postings about a new Krispy Kreme that opened in the neighborhood. Cars can line up for blocks waiting to get into a Krispy Kreme outlet. Little old ladies with blue hair will run people over with their shopping carts in a mad scramble to get the one remaining box of Krispy Kreme’s.

Why, in certain parts of this country, if you come between a Man or a Woman and their Krispy Kreme, they’ll shoot you.

And on that bit of cultural exchange, I think I’ll sign off and get to work for the day. Beautiful clouds across the Bay today, as shown in this photo snapped with my handy Nikon 995 digital.

P.S. Just joking about that shooting part. Really. Honest. Cross my heart.