Below, the goal, objective, scope, and product for a position paper are specified along with a suggested strategy for writing a public comment.
Knowledge of administrative procedures for implementing law, including the public’s role in implementation
To influence the administration of a law by contributing information relevant to standard-setting, rule-making, or permitting
A formal written comment
Limited to the specific proposed administrative action.
Base comments on your authority to respond, whether based on personal experience, organizational advocacy, vocational or professional background, or specialized knowledge.
While expert commentary is always appropriate, you need not be an expert in order to comment. Administrators want and need to hear from anyone who can make a useful comment. There is no template for public comments, unlike legal briefs. A simple letter can have an impact. If friends or a community organization shares your views, you might want to present a collective comment. You might sign for the group, or all individuals involved might sign, or the organization’s officers might sign.