We appreciate the many responses we received on our previous post regarding Regulation 2.0; several of you asked for our views regarding CRE priorities regarding the social media.
Here they are:
Pre and Post Comment Period
The laudable efforts to date regarding utilizing the social media in rulemaking deal with a very small slice of the rulemaking pie, namely the notice and comment period. However the life of a rulemaking is considerably longer than the often used sixty-day comment period, namely the months — if not years–of agency work during the pre and post comment period. We are not aware of any significant activity in this space.
Bottom-Up not Top Down
The essence of social media is to provide for “community” involvement in a particular issue. A central government is most certainly capable of serving as a catalyst for the development of the said communities but such efforts should be focused on a “bottom-up” approach which would involve the central government providing a forum for existing social media communities to broadcast their approaches and to learn from the experiences of others. Efforts to date have been decidely “top down”.
Finally the emphasis on participation by the general public is somewhat overemphasized; more specifically two career households with two children and four soccer games per week hardly have time to read the Federal Register. However public participation by affected stakeholders during the post comment period is important and should be emphasized–presently it is not being addressed by leaders of the movement.
More specifically affected stakeholders should be given the opportunity to scruntinize the views of other commenters and the regulators should be presented with a discretionary opportunity to review such comments. Interactive Public Dockets were developed to fufill those demands.
See the website eRulemaking.US for additional information.