Submitting Comments to Federal Agencies
Submitting Comments to Federal Agencies
August 4, 2011
Last month, APTS scored an important win when our formal comments to the U.S. Department of Education (ED) on the Promise Neighborhoods program resulted in a change that makes clear the value of public television stations in these efforts and increases the potential of public television to be strong partners in these grants. But how do changes like this happen? And how can stations play a role?
When agencies clarify federal law – through regulations or a competitive grant process, for instance – they are usually required to operate an official public comment period. A formal, official notice is placed in the Federal Register announcing the proposed priorities and the beginning of a public comment period. Along with their proposal, the agency will announce a deadline and detailed instructions on submitting comments. Comments submitted are sometimes made available on ED's website, but they are often not readily available. On behalf of the stations we represent, when there is an appropriate opportunity, APTS drafts and submits comments that reflect the priorities and strengths of the public broadcasting community. We tailor our asks to each proposal, but our requests often involve emphasizing literacy and numeracy, demanding digital components in every education initiative and incorporating local outreach and communication.
Though the Grant Center takes the lead in drafting these comments, our partners at CPB and PBS often collaborate and sign on to these comments, where appropriate. This is one of the many ways in which the Grant Center works to educate federal policymakers about the important and effective work being done by local stations and to open doors for opportunities for public broadcasters. When we are successful, stations become more competitive candidates and more valuable partners.
Shaking things up, ED recently introduced a “blog-style” comment form for the Race To The Top -- Early Learning Challenge. While public comment has always been inherently public, this new method makes all comments immediately public, making it more likely that fellow commenters and Ed.gov passersby will read what we write, instead of just the ED official to whom we sent previously sent comments. This has also made comments more informal. It is unclear how often departments will utilize this commenting style in the future.
Stations are welcome to submit their own comments on each and every proposal. APTS can speak for stations in a collective letter, but it is also powerful when stations amplify the message by bringing their voice to agencies. The Grant Center website will be updated with opportunities to comment whenever there are new draft priorities released. While we never know precisely when agencies will announce grant opportunities and request comments, we can predict what's next on the docket. Soon, ED may announce their priorities for the third round of Race To The Top (not to be confused with the Race To The Top – Early Learning Challenge). And in the coming months, if legislation is reauthorized or if new legislation is passed, responsible agencies may be providing program regulations, along with a comment period. The Grant Center will keep you apprised of upcoming opportunities.
Furthermore, the more we know about what you are working on, the better we can tell your story and call attention to station priorities in comments we write on behalf of the public broadcasting community. Share your stories and expertise with grantcenter@apts.org.
