A coalition of state and local government organizations today urged President Donald Trump to pause comment periods on both active rulemakings and nonrulemaking notices across the federal government until the global COVID-19 pandemic subsides.

A comment period, in the context of administrative rulemaking, is a timeframe in which members of the public can submit written feedback to a federal agency regarding a proposed rule.

According to a coalition letter:

State and local government policymakers’ thoughtful input into proposed federal agency actions is a vital component of our democratic system and provides federal agencies with much-needed perspectives and potential impacts of federal actions.

We recognize that our members are facing massive challenges in responding to, and as a result of, this global pandemic. At present, regulations.gov acknowledges nearly 700 open comment periods that will close in the next 30 days and more than 1000 over the next 90 days. Regulations.gov stated vision of its eRulemaking Program is “to enable the public ease of access to participate in a high quality, efficient, and open rulemaking process.” The extreme impact on normal working and living conditions will impair the ability of not only state and local officials, but also the general public, issue experts and others to provide thoughtful and meaningful participation and involvement in potential federal government actions that directly affect millions of people.

Consistent and meaningful engagement and consultation between intergovernmental partners is vital in the development and implementation of effective policies, programs and regulations. Therefore, state and local governments urge you to extend agency comment periods for a reasonable period of time, which will allow our state and local policymakers to focus on addressing the nation’s immediate pandemic response needs and ensure their ability to devote proper consideration of agency regulations. Thank you for your consideration.

Most respectfully,

National Governors Association
National Conference of State Legislatures
The Council of State Governments
National Association of Counties
National League of Cities
The United States Conference of Mayors
Government Finance Officers Association
International City/County Management Association
National Association of State Auditors, Comptrollers and Treasurers

Stay tuned to Conduit Street for more information.

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