The Power of Public Comment
TRC Blog

The Power of Public Comment

Posted Jan 18, 2018 by Ryan Kiscaden

The city of Philadelphia recently issued a 55-page report, “Power Our Future: A Clean Energy Vision for Philadelphia.” It was an admirable undertaking, attempting to develop and articulate a plan that was logical, workable and most important, responsive to energy and environmental concerns for the city’s long-term future.

We should commend them for the effort. However, the alarm bell started ringing when I read this sentence: “Buy a programmable thermostat to reduce energy usage when you’re away from home.” On the surface, a sensible suggestion. However, what was lacking is any advice that a consumer or business should follow if they were replacing a mercury-filled unit.

Philadelphia, which is near TRC’s corporate offices, correctly offered the opportunity to provide public comment on their preliminary report. I did so in a three-page letter (with four pages of documentation), drawing their attention to existing state and federal mandates regarding the disposal and recycling of mercury thermostats and explaining in detail the significant role that TRC has played in this effort. My fact sheets provided a listing of wholesalers who are part of the TRC network and who cover all of Philadelphia. In short, part of my reply was a local answer to a local issue, a thumbnail sketch of our input at a limited effort in TRC’s backyard.

There exists a broader issue here, leading me to suggest everyone in our industry should be constantly vigilant regarding issues, often in a legislative vein that might affect our industry. Offering public comment makes sense, and we should pay assiduous attention to every opportunity when it presents itself. At the risk of belaboring the obvious, in most instances, the time to offer feedback, insight and suggestions is before legislative bodies pass a law or issue a final report.

One other recommendation worth mentioning is that when we promote our suggestions or ideas, we do so in a manner that is neither accusatory or negative. Legislators and report writers are not perfect and rarely are experts on the topic. Sometimes consultants write the report with the influence of the sponsors. This is where we play a vital role in being the knowledgeable, informative choice. They will find it difficult to dismiss us if we present the information in a tactful and thorough fashion.

There is another factor to consider when pondering your input for public comment. From a news perspective, exceptional journalists are thrilled when they discover a “source” or expert that had been heretofore unknown to them. It gives them a deeper and broader pool of expertise. Legislators and those who issue a report are not journalists, but they too — if they are transparent and open-minded — should be willing to embrace an organization that can add substantive accuracy to the topic under discussion.

When I submitted TRC’s input, I was careful to substantiate our efforts with documented evidence that a problem could exist and that we were the no-cost answer of choice to ameliorate the problem.

Participating in public comments can be a blessing in disguise. It allows industry stakeholders to provide a well-documented stance on issues and it positions us as an expert on the subject.