Critical Need for Your Comments – USDA IFR

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The deadline for submitting public comments on USDA’s Interim Final Rule on Domestic Hemp Production is on January 29th, 2020, at 11:59pm ET.  

Comments may be submitted online at regulations.gov and may either be uploaded to the site as a PDF or Word file, or copied and pasted into the text window provided on the site.

So far about 2300 comments have been submitted; it is critical that the Department receive as many unique and substantive comments as possible.

PUBLIC COMMENTS MATTER!  Even though the interim rule has already been made effective, USDA must still finalize it before it becomes permanent, and they are required to take into account—and respond to—all substantive comments submitted by the public.

Comments need not be lengthy, or beautifully written.  But in order to be taken into account, they must be substantive, unique (no form letters), and clearly state how the rule directly impacts the commenter’s personal and/or business interests.  These are the key points a comment should cover:

  • Identify a specific issue, topic or provision in the rule, state how it impacts you directly, and suggest an alternative that would better serve or protect your interests.
  • Identify credentials and experience that support your position. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, farmer, distributor, retailer, etc.), say so.
  • Support your position with specific examples from your personal experience: how does the rule impact you or your business?  What specific costs, burdens or missed opportunities result?
  • It certainly helps if you also have concrete information about the rule’s impacts to others in your community or field of business, but with 3 days left to submit it’s fine to skip the research paper and simply write from your own experience.  That is ultimately the most powerful story to tell.

Check out our policy memo discussing the rule’s impacts to hemp producers.  While commenters are free to repeat some of the same arguments, it is important that all commenters indicate in their own words how the rule specifically impacts them.

Hemp Needs YOU

The USDA needs to hear from you, and the time is now. Don't wait for someone else to do it. The entire industry is waiting on YOU to comment.

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