Kate and I recently submitted a brief formal Comment on the EPA’s 2022 “Proposed Interim Decisions for the Rodenticides“. First time doing something like this, and miscellaneous guidelines on effective commenting strategies and retrospective (and therefore with questionable causal interpretation) study of Commenting effectiveness, it was still rather unclear to me how to write one of these, at least in the short time we had to write it. Lessons for next time, I suppose. Would that it have been on lab animal regs and we’d have been much better set!
Regardless, our comment’s attached below, in case the formal Comment is not accepted. Anticoagulant and other rodenticides have long been one of my go-to example for straightforward ways to improve the lives of wild animals (in the class of Pareto improvements across all sacred goods w/ similar $ costs), so it was nice to compile some of those well-worn points within a single document, even operating under various constraints!
In writing the Comment we tried to strike a few separate balances, also taking into account the population of existing Comments already approved on the Notice. Many of them fell at one of two extremes, either appealing to strong personal emotion and with moralizing language, or else writing in a stilted, vague, and scientistic style presumably meant to signal something like respectability and credibility. To the extent that comments we read attempted to demonstrate something like rodent personhood and rodenticide effects, it was usually with a generic declaration followed by reference to more philosophical work. Taking our comment in this context, we tried to focus our efforts on building a case for these with a bit more detail, in a style that optimistically erred closer to the conversationally punchy than the shrill. Under binary decision-making, it’s easy to show the benefits of trading a bit of your first moment for your second, and we wanted to situate our own statement as part of a greater, diversified Commenting strategy.
In terms of straddling a line between the personal and the professional, we also included a few basic graphical flourishes — comments we read often followed questionable typesetting & formatting practices. If the medium is the message, we hoped to convey a certain attention to detail while also not being too extra. Hopefully that came across!
edit: and ofc I notice some of my quotations are pointing the wrong way (from mistyping ” instead of “). Edited the above w/ corrections, but too late for the formal comment, darn 🤦
nikvetr 