October 11, 2012
I object to the procedurs established for this meeting.
As an initial matter, notice was not timely given to the public. The notice is dated October 9, 2012. The Government in Sunshine Act requires that agencies provide notice at least one week before a meeting date. 5 U.S.C. Sec. 552b(e). Even if the Committee is not subject to that requirement, three days notice of a meeting to discuss and vote on important rulemaking recommendations clearly does not provide the Committee with the opportunity to obtain considered public input.
More importantly, the request for public comment appears to be a mere formality rather than a serious attempt to obtain input. How can the public provide comment on the subcommittee recommondations to be considered by Committee when those recommendations have not been made available to the public?
I strongly urge the Committee to reform its procedures to: (i) ensure that adequate advance notice is given to the public of all meetings (ii) make subcommittee recommendations available to the public sufficiently in advance of Committee meetings so that there is a meaningful opportunity for public comment and (iii) require disclosure of circumstances in which Committee members have potential or actual conflicts of interest or lack independence.