Submitting comments on rulemakings

["Bradt, Clayton" <Clayton.Bradt@Labor.State.Ny.Us>]

Bill Lipton wrote:



"Thus, when BRC became an issue, the shear number of

negative comments influenced  the NRC to rescind this."



I think it was congress that stopped NRC from promulgating BRC.  No doubt

congress were influenced by the number of negative comments from their

constituents in determining to stifle the commission's actions.  My

experience is that NRC indulges comments that further its predetermined

purposes and is dismissive of comments that don't.  Remember, the

commission's real constituents are in congress. Once given their marching

orders by the oversight committees, the commission will promulgate the

necessary regulations come hell or high water.  A comment will never

influence the outcome of a rulemaking unless it resonates with a power

center internal to the organization that can use it as a pretext to further

a specific aim.  The intellectual merit of a comment is largely irrelevant

to its reception. 



Clayton J. Bradt, CHP

Principal Radiophysicist

NYS Dept. of Labor

Radiological Health Unit

voice: (518) 457-1202

fax:    (518) 485-7406

e-mail: usccjb@labor.state.ny.us



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