Thanks for the info(I think). But the real question remains.. does the public suggestions/comments acutally affect the pr outcom? At the very least can it be delayed? Do they really consider our opinions before rubber stamping it? Has there ever been a case where there was such major opposition that a pr was actually dropped?
WV-Girl, Miss Piggy, and all,
Having been involved in some Agency rule-making in the past, I may have something to contribute here (cause it’s certainly not my investing prowess !
)
First, my disclaimers :
1. I’ve only been involved on the fringes, usually from just the technical side....never been deeply involved by being one of the "inside the Beltway"-types.
2. Every Agency does things a little different....my experience may not match how the Board does their rule making.
Anyway, here are my comments :
For a good basic review of the rule making process, as well as current and past rule making, there is a good gov’t site here :
www.regulations.gov Check out the FAQ under "How to Use This Site" for basic info on the process, etc.
It’s not mandatory that an Agency use this site, but many do....I see the FRTIB (Federal Retirement Thrift Investment Board) DOES have many items posted...you can do a search on "FRTIB" to see ‘em
The Bad News :
Although every comment should be addressed, very rarely (if ever !) do individual comments to the docket carry much weight. Usually, all the comments that come in and raise the same issue on the proposal are lumped together, and addressed with one response....volume/number of responses making a point doesn’t seem to matter. That one response is usually targeted to support the rule making’s conclusion...which makes sense (if you think about it objectively), since the "goal" is to refute the point, not address the number of responses !
Lawyers control the process (surprise, surprise !) The "wordsmithing" is unbelievable !
The Good News
The web site noted above has an alert notification one can sign up for, so we should be able to find out when the FRTIB posts their proposal (assuming they use the site this time !) Also, comments to the docket can be submitted on-line, making it easier for us to submit our concerns.
A typical rule making affects an Agency’s area of operation, and thus generate a relatively small number of responses.....since the changes by the FRTIB affect ALL Fed employees, and retirees, I can see a boatload of comments to the docket coming in (BUT....see above !)
In my experience, comments from organizations (like the ETAC, unions, etc) have more impact than individual comments.
All rule-making that I’ve been involved with has had to go through OMB for "approval" or sign off...that may be another avenue to make us heard, by contacting OMB...just a guess, though.
This is a political process ! The FRTIB is a "political" body... IMHO, one question from a Congress member (House or Senate) is worth way more than either an individual comment OR an organizational comment ! The point being....while it’s great to contact the FRTIB or the reps on the ETAC, you might also consider contacting your elected rep to Congress....particularly in those areas that have a large number of Fed employees, like Maryland and Virginia (and who seem to be particularly sensitive when they start dorking around with Fed employees !) Also, when the head of an Agency is a political appointee, and they are questioned by Congress, they become much more sensitive to which way the political wind is blowing....and may "sit" on the rule-making until the crap blows over, or kill it altogether....
Anyway, I hope this helps.....
Stoplight...
I suspect it means, though, that we MAY have to wade through every agency's postings, until we see the one we want ! Once the FRTIB's announcement is out, and a specific docket number is established, then we can use the "email notification" feature to keep up to date.....make sense ????
